Bonerb v. Richard J. Caron Foundation

Bonerb (plaintiff), a New York resident, was injured at a basketball game at a Pennsylvania drug-rehabilitation facility owned by the Caron Foundation (defendant). His original complaint alleged the basketball court was negligently maintained. He later sought to amend to add a counseling-malpractice claim. The defendant objected that the new claim did not relate back and was barred by Pennsylvania's two-year statute of limitations.

Whether a claim for counseling malpractice relates back to an original negligence claim where both arise out of the same injury to the plaintiff.