Costello v. Casler

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Justia Opinion Summary

Debbie Costello and Philip Casler were involved in an automobile accident, after which Casler died from unrelated causes. Costello submitted a claim with Casler's insurance provider, American Family, for injuries relating to the accident. After the statute of limitations expired, Costello submitted a motion in the district court pursuant to Nev. R. Civ. P. 25, seeking to substitute the special administratrix of Casler's estate for Casler. American Family submitted a countermotion for summary judgment, arguing that any amendment adding a party was now time-barred because the statute of limitations had expired. The district court granted Casler's countermotion for summary judgment. The Supreme Court reversed, holding (1) under Nev. R. Civ. P. 15(c), an amendment to a complaint adding a decedent's estate as a party to an action will relate back to the date of the original pleading filed prior to the expiration of the statute of limitations; and (2) a decedent insurer's notice and knowledge of the institution of an action may be imputed to the decedent's estate for purposes of satisfying the relation back requirements of Rule 15(c). Remanded.

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