Worthington v. Wilson

Worthington (plaintiff) sued the Village of Peoria Heights and 'three unknown named police officers' within the statute of limitations for injuries suffered during his arrest; five months later he amended the complaint to name Wilson and Wall (defendants) as the actual officers, dropping the Village as a defendant. Wilson and Wall, who learned of the suit within 120 days of its filing, moved to dismiss, arguing the amendment fell outside the statute of limitations and could not relate back to the original filing.

Whether an amended complaint relates back to the original for statute-of-limitations purposes if the plaintiff named fictitious defendants and the complaint was amended after the limitations period expired.