Law Practice,
Appellate Practice
May 6, 2022
Ignorance isn’t bliss, but it will relate back
The Appellate Court stated that the “[t]est is whether, at the time the complaint was filed, the plaintiff “was ignorant of the facts giving [her] a cause of action against the person.”
The Appellate Court recently issued a ruling that should make plaintiff attorneys a little less anxious when naming a Doe defendant in pending litigation. Oftentimes, when a plaintiff attorney names a Doe defendant, there is concern about whether the plaintiff knew of the Doe defendant’s existence and, consequently, does the statute of limitations “relate back” to the filing of the complaint. Well, the Appellate Court’s decision in Susan Hahn, et al. v. New York Air ...
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