David v. Crompton & Knowles Corp.
United States District Court for the Eastern District of Pennsylvania
58 F.R.D. 444 (E.D. Pa. 1973)
David (plaintiff), injured by a shredding machine, sued Crompton (defendant), alleging Crompton designed, manufactured, and sold the machine to his employer; Crompton initially answered that it lacked sufficient knowledge to admit or deny that allegation, but later moved to amend its answer to affirmatively deny manufacturing the machine, claiming it had since learned the machine was actually made by a company (Hunter) before Crompton acquired it and that Crompton hadn't assumed liability for pre-acquisition design defects. By the time Crompton sought this amendment, the statute of limitations had run against David's ability to sue Hunter directly.
Whether a court may deny a request to amend an answer if the amendment will result in the expiration of the statute of limitations when the statute would not have otherwise expired in the ordinary course of the proceedings.