Davaloo v. State Farm Insurance Co.
California Court of Appeal
37 Cal. Rptr. 3d 528 (2005)
Under a statute reviving certain 1994 Northridge earthquake insurance claims through December 31, 2001, plaintiffs (plaintiffs) filed nearly identical, generic complaints against State Farm (defendant) on the filing deadline containing no specific factual allegations — no addresses, policy numbers, or details about any claim or denial — and after State Farm demurred, the plaintiffs filed amended complaints with actual facts in 2003; the trial court found the amended complaints did not relate back to the timely-filed original complaints and were therefore time-barred.
Whether an amended complaint relates back to a timely original complaint if it rests on the same general set of facts as the original complaint.