Motor Vehicle Law: Court holds that relation back doctrine applies to plaintiff’s amended complaint and saves the new allegation from being time barred by Connecticut General Statutes § 52-584

The plaintiff seeks to amend his complaint to add an additional allegation, and the defendant objects on the grounds that the new cause of action set forth in the amended complaint is time barred by the two-year statute of limitations set forth in Connecticut General Statutes § 52-584. This action arises from an incident in which the plaintiff’s vehicle was struck by a vehicle owned by Waterview Landscaping, LLC.

Request to Amend Complaint

The plaintiff filed a request for leave to amend his complaint to include an allegation that Waterview was negligent in “leaving the keys in the unlocked vehicle [which] resulted in the foreseeable theft of the said motor vehicle and the ultimate harm and resulting injuries to the plaintiff….” In response to the defendant’s objection, the plaintiff argues that his amendment should be allowed because his claims against Waterview “relate back” to his original complaint.

The relation back doctrine is well established by the Connecticut Supreme Court. A party may properly amplify or expand what has already been alleged in support of a cause of action, provided the identity of the cause of action remains substantially the same. The relation back doctrine provides that an amendment relates back when the original complaint has given the party fair notice that a claim is being asserted stemming from a particular transaction or occurrence, thereby serving the objectives of the statute of limitations, namely, to protect parties from having to defend against stale claims.

The Relation Back Doctrine

Where the proposed allegations promote a change in or an addition to a ground of negligence arising out of a single group of facts, the courts have allowed use of the relation back doctrine. On the other hand, where new allegations directly contradict those in the operative complaint, the courts hold that they do not relate back to the operative complaint.

Court’s Conclusion and Granting of the Request

In this case, the court finds that the factual allegations of the plaintiff’s original complaint and the factual allegations set forth in the proposed amended complaint are sufficiently related to warrant application of the relation back doctrine. Although the original complaint alleges that the Waterview vehicle was being operated with Waterview’s permission or as Waterview’s agent, servant, and/or employee, the court concludes that the essential issue remains the same for both claims, namely, how and under what conditions did the individual defendant obtain access to Waterview’s vehicle.

The new allegation involves the same relevant time period, the same location, the same injuries, the same actors, and the same type of evidence will be required to prove the allegations. The court does recognize that this case presents a close question regarding whether Waterview’s alleged negligence in leaving the keys inside an unlocked vehicle constitutes a separate cause of action from the vicarious liability theory underpinning the plaintiff’s original complaint.

However, construing the allegation in both complaints broadly and realistically, rather than narrowly and technically, and in a manner intended to advance substantial justice, the court concludes that the plaintiff should be permitted to amend his complaint because both claims arise from a single group of facts. The plaintiff’s request for leave to amend is therefore granted.

Karabetsos v. Arbella Prot. Ins. Co., Inc., No. HHD-CV-23-6174876-S, 2024 WL 4541674 (Conn. Super. Ct. Oct. 17, 2024)