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Update: In what circumstances does an amendment to a complaint relate back John Doe defendants?

Judge Nelson recently considered the relation back issue in the context of DPPA claims where a plaintiff first named numerous John and Jane Doe defendants and later amended to name specific individuals. Judge Nelson held that claims asserted against defendants previously identified as “John Does” did not relate back for purposes of Fed. R. Civ. P. 15(c)(1)(C). In light of Judge Nelson’s decision—and other recent decisions in this District—any plaintiff seeking to invoke Fed. R. Civ. P. 15(c)(1)(C) to revive otherwise untimely claims asserted against former John Doe defendants will face a significant uphill battle.  Rollins v. City of Albert Lea, 14-CV-299 (SRN/HB) (D. Minn. Nov. 17, 2016); Karasov v. Caplan Law Firm, P.A., 14-CV-1503 (SRN/BRT) (D. Minn. Nov. 18, 2016).