Moore v. Walton, No. 18-1868 (3d Cir. 2024)
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In a case before the United States Court of Appeals for the Third Circuit, the plaintiff, Troy Moore, Sr., a prisoner, sued Correctional Officer Saajida Walton under 42 U.S.C. § 1983, alleging that she violated his Eighth Amendment rights. The claim was based on an incident where a toilet in Moore’s prison cell exploded and Walton refused to let him out of his cell to clean up for over eight hours. Moore originally filed the complaint under a misspelled version of Walton’s name. The correct spelling was not provided until after the statute of limitations for his claim had expired. The District Court granted summary judgment to Walton based on the statute of limitations.
The Circuit Court held that the District Court misapplied the relation back analysis under Federal Rule of Civil Procedure 15(c)(1)(C) by failing to consider the period for service provided by Federal Rule of Civil Procedure 4(m). It held that Rule 15(c)(1)(C)’s reference to “the period provided by Rule 4(m)” includes any extensions for service granted under Rule 4(m) for good cause. The case was remanded to the District Court to determine whether Walton received notice of the action by a certain date and, if so, whether Moore could demonstrate the absence of prejudice—the final element necessary to satisfy the relation back inquiry. If all these conditions were met, the District Court would then need to consider the merits of Moore’s Eighth Amendment claim.
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