Krupski v. Costa Crociere S.P.A.

Wanda Krupski (plaintiff) was injured aboard a cruise ship, with her ticket listing "Costa Cruise" on the front but identifying Costa Crociere S.p.A. (defendant) as the carrier on the back. She sued Costa Cruise before the statute of limitations expired, and only after the limitations period ran did Costa Cruise repeatedly point out that Costa Crociere was the proper defendant. Costa Cruise moved for summary judgment on that basis, and Krupski cross-moved to amend her complaint to add Costa Crociere; the district court granted her leave to amend, the parties stipulated to dismiss Costa Cruise, and Krupski filed her amended complaint against Costa Crociere. Costa Crociere then moved to dismiss, arguing the amendment didn't relate back to the original filing date and was thus time-barred; the district court agreed, and the Eleventh Circuit affirmed based partly on Krupski's own awareness of Costa Crociere's identity and her delay in amending.