KRUPSKI v. COSTA CROCIERE S. P. A
The Supreme Court ruled that a woman who sued the wrong corporate affiliate of a cruise line after tripping on board can still add the correct company as a defendant, even though she did so after the filing deadline passed.
The Court held that what matters is whether the newly added company knew or should have known it was left out of the original lawsuit only because of a mistake — not whether the injured passenger herself knew of the company's existence or how quickly she acted to fix the error.
“The question under Rule 15(c)(1)(C)(ii) is not whether Krupski knew or should have known the identity of Costa Crociere as the proper defendant, but whether Costa Crociere knew or should have known that it would have been named as a defendant but for an error.”
The Court's central holding on whose knowledge matters for relation back.
How it got here: The district court and the Eleventh Circuit both ruled that adding Costa Crociere came too late; Krupski asked the Supreme Court to resolve a circuit split over the rule.
The Case in Depth
What happened
Wanda Krupski broke her leg tripping over a cable on a cruise ship. Her ticket named Costa Crociere S.p.A., an Italian company, as the carrier, but also prominently featured Costa Cruise Lines, its Florida-based marketing agent. Krupski sued Costa Cruise Lines before the one-year deadline, but Costa Cruise later revealed that Costa Crociere was actually responsible, and she sought to add Costa Crociere as a defendant only after the deadline had passed.
The question before the Court
After a cruise passenger sued the wrong "Costa" company by mistake, could she add the right company as a defendant after the filing deadline had passed?
Why it matters
Plaintiffs who sue the wrong corporate entity among related companies with similar names get more breathing room to fix that mistake without losing their case to the statute of limitations, as long as the correct company should have realized the mix-up was a mistake rather than a deliberate choice. This especially helps consumers navigating confusing corporate structures like parent companies, subsidiaries, and marketing agents.
What changes now
The case is sent back to the lower courts for further proceedings consistent with the Supreme Court's interpretation of Rule 15(c)(1)(C). Krupski's amended complaint against Costa Crociere will now be treated as timely, allowing her negligence claim to proceed on the merits rather than being barred by the statute of limitations. This is a final decision on the relation-back question, not a temporary order.
What this does not decide
The Court did not decide whether Krupski's claim against Costa Crociere will ultimately succeed on the merits — only that her amended complaint counts as timely filed. It also did not adopt a rule that any mistaken choice between two known parties automatically qualifies; the specific facts showing Costa Crociere should have suspected a mistake mattered.
Concurrences and dissents
Concurrence — Justice Scalia
Justice Scalia agreed with the Court's interpretation of Rule 15(c)(1)(C) and joined the judgment, but objected to the majority's reliance on the Advisory Committee's Notes as evidence of what the Rule means. He argued that such notes are useful only as scholarly commentary, not as authoritative sources of a rule's meaning, because only the text of the Rule itself controls.
How the Court got there
The legal reasoning, step by step
- The Court focused on the text of Rule 15(c)(1)(C)(ii), which lets an amended complaint naming a new defendant 'relate back' to the original filing date — treating it as timely — if the new defendant knew or should have known, within about 120 days of the original filing, that it would have been sued but for a mistake about who the proper party was.
- The Court held that the relevant knowledge is the new defendant's, not the plaintiff's: the question is not whether Krupski knew or should have known Costa Crociere was the right company, but whether Costa Crociere knew or should have known it escaped the original lawsuit only by mistake.
- The Court rejected the idea that simply knowing a party exists rules out a 'mistake concerning the proper party's identity.' A plaintiff can know both companies exist yet still misunderstand which one actually played the relevant role — that misunderstanding is itself a mistake under the Rule.
- Because Krupski's original complaint described conduct that matched Costa Crociere's actual role (owning and operating the ship) while mistakenly attributing it to Costa Cruise, and because the two companies had similar names and shared counsel, the Court concluded Costa Crociere should have realized the omission was a mistake.
- The Court also rejected using the plaintiff's delay in seeking to amend as a separate basis to deny relation back, holding that Rule 15(c)(1)(C) lists an exclusive, mandatory set of requirements that does not include the amending party's diligence or speed.
Doctrinal impact
Cases affected by this decision
Distinguishes Nelson v. Adams USA, Inc. (529 U. S. 460)
The Court said this earlier case involved a deliberate, informed decision, not a mistake, so it does not control here.