Tran v. Alphonse Hotel Corp.
United States Court of Appeals for the Second Circuit
281 F.3d 23 (2d Cir. 2002)
Relevant factsFree
Tran (plaintiff) originally sued his former employers (defendants) in 1991 for unpaid wages under the FLSA, and years later, after discovering evidence of union-official bribery, moved in 1997 to add a RICO claim; the district court allowed the amendment, finding the RICO claim related back to the original 1991 complaint despite RICO's four-year limitations period having otherwise expired, and ruled for Tran.
IssueFree
Whether an amendment adding a new claim not arising from the facts alleged in the original pleading relates back to the date of the original filing.