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Federal "Relation Back" Doctrine Intended To Expand, Not Limit, Prisoners' Rights

New Jersey State prison officials, guards and riot team personnel (defendants) moved for summary judgment dismissal of an amended 42 U.S.C. § 1983 complaint following a 30 day lockdown at the Bayside Prison. The amendment allowed an already released prisoner (Goolsby) to become a plaintiff in the suit and another plaintiff (Lopez) to include supervisory claims against officials. The motion was denied.

Bayside Prison was placed on a lockdown after a prisoner killed a guard in 1997. Several hundred prisoners filed a § 1983 action alleging civil rights violations by facility and specially trained riot guards in July, August and September of 1997. A motion to amend the complaint was granted in 1999 allowing Goolsby's participation and Lopez's addition of the supervisory claims. The defendant's motioned for the amendment's dismissal arguing that the "Relation Back" doctrine under the Federal Rules of Civil Procedure, Rule 15(c), should preclude Goolsby's participation because he did not exhaust his administrative remedies pursuant to the Prison Litigation Reform Act. The defendants further alleged that the supervisory officials were not aware of, and did not order, violations of the prisoners' rights.

The U.S. District Court for the District of New Jersey held that granting the dismissal would "bar Plaintiffs from bringing a claim that, but for the relation back doctrine, Plaintiff would indisputably be entitled to bring without having first exhausted his administrative remedies." The court held that the doctrine was intended to expand, not limit, a plaintiff's rights and to "ameliorate the harsh result of the strict application of the statute of limitations." The court further held that sufficient facts were shown to suggest deliberate indifference by the officials due to their non action considering the numerous medical injuries dealt with during the lockdown and the circumstances leading to it. In 2000, the class action certification was denied but the individual cases were allowed to proceed. See: In re Bayside Prison Litigation, USDC, D.N.J., Case No. 97 5127 (RBK), 2007 U.S. Dist. LEXIS 7096 (2007).

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Related legal case

In re Bayside Prison Litigation

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