8 F.3d 1253 (7th Cir. 1993)
Worthington v. Wilson is a staple Seventh Circuit decision on Federal Rule of Civil Procedure 15(c)'s relation-back doctrine, particularly in the recurring context of § 1983 suits that begin with "John Doe" police officers because a plaintiff does not yet know the officers' identities.
Does an amendment substituting named individual officers for previously pleaded "John Doe" defendants in a § 1983 action relate back under Federal Rule of Civil Procedure 15(c) when the plaintiff's original failure to name those officers stemmed from lack of knowledge, and the newly named defendants did not receive notice within the Rule 4 service period?
Under Federal Rule of Civil Procedure 15(c) (as then in effect), an amendment that changes the party or the naming of the party against whom a claim is asserted relates back to the date of the original pleading if: (1) the claim arises out of the same conduct, transaction, or occurrence set out in the original pleading; (2) within the period provided for service of the summons and complaint (120 days from filing), the party to be brought in by amendment received such notice of the action that it will not be prejudiced in defending on the merits; and (3) the party to be brought in knew or should have known that, but for a mistake concerning the proper party's identity, the action would have been brought against it. In the Seventh Circuit, a plaintiff's lack of knowledge of a defendant's identity (as reflected by using "John Doe" placeholders) is not a "mistake" within the meaning of Rule 15(c); and notice to a municipality or institutional defendant does not, without more, constitute timely notice to individual officers for purposes of relation back.
No. The amendment did not relate back. Substituting named officers for "John Doe" defendants did not satisfy Rule 15(c)'s "mistake" requirement, and the newly named officers did not receive the requisite notice within the service period. The claims against the individual officers were therefore time-barred.
Worthington v. Wilson is frequently cited for the proposition that substituting named defendants for "John Doe" placeholders does not, by itself, satisfy Rule 15(c)'s relation-back requirements in the Seventh Circuit. It teaches that plaintiffs must diligently identify and notify the correct defendants before the statute of limitations runs and within the service period. For students, the case is a vital illustration of how procedural rules can control substantive outcomes—especially in § 1983 litigation—and how courts construe the term "mistake" narrowly when a plaintiff's problem is not misidentification but nonidentification. Even after Krupski v. Costa Crociere (2010) clarified the focus of the "mistake" inquiry, Seventh Circuit precedent continues to treat pure lack of knowledge as distinct from, and insufficient to establish, a Rule 15(c) mistake.