Ceara v. Deacon, No. 17-569 (2d Cir. 2019)Annotate this Case
Ceara, a state inmate who claims that he was assaulted by a prison corrections officer, filed a pro se complaint raising claims under 42 U.S.C. 1983, naming “John Doe” as the officer who allegedly assaulted him but also described and named that officer as “Officer Deagan.” After the statute of limitations had expired, Ceara amended his complaint to correctly name “C.O. Deagan” as “Officer Joseph Deacon.” The district court dismissed on the ground that an amended complaint identifying a defendant to replace a “John Doe” placeholder does not relate back to the original complaint under Federal Rule of Civil Procedure 15(c)(1)(C). The Second Circuit vacated and remanded. Ceara’s complaint was not a true John Doe complaint; his amendment to correct a misspelling related back under 15 Rule 15(c)(1)(C).