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16 New York opinions name it 2 courts 2010–2026 13 in the last five years
The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Petruzzi v. Purowgreen2 sentences2026"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( i.d. , quoting Petruzzi v Purow , 180 AD3d 1083, 1084 [2d Dept 2020]; Alvarado v Beth Israel Med. 2025"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Petruzzi v Purow , 180 AD3d 1083, 1084 [internal quotation marks omitted]; see Buran v Coupal , 87 NY2d at 180 ). | 6 | 7 |
Buran v. Coupalgreen2 sentences2025"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Petruzzi v Purow , 180 AD3d 1083, 1084 [internal quotation marks omitted]; see Buran v Coupal , 87 NY2d at 180 ). 2023In order to establish the applicability of the relation-back doctrine, the plaintiff must demonstrate that: (1) the causes of action arose out of the same conduct, transaction, or occurrence; (2) the new party is united in interest with one or more of the original defendants, and by reason of that relationship can be charged with such notice of the institution of the action that he or she will not be prejudiced in maintaining his or her defense on the merits; and (3) the new defendant knew or should have known that, but for a mistake by the plaintiff as to the identity of the proper parties, t | 3 | 5 |
Alvarado v. Beth Israel Medical Centergreen2 sentences2026Ctr., 60 AD3d 981, 982-983 [2d Dept 2009]). 2023Ctr. , 60 AD3d 981, 982 [internal quotation marks omitted]). | 3 | 3 |
Kunwar v. Northwell Healthgreen2 sentences2025"Notice to the new defendant within the applicable limitations period is the linchpin of the relation-back doctrine, and thus the third prong of the test focuses, inter alia, on whether the defendant could have reasonably concluded that the failure to sue within the limitations period meant that there was no intent to sue that person at all and that the matter has been laid to rest as far as he or she is concerned" ( Kunwar v Northwell Health , 229 AD3d 528, 531 [internal quotation marks omitted]; see Shapiro v Good Samaritan Regional Hosp. 2025"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Sanders v Guida , 213 AD3d 712, 715 [internal quotation marks omitted]; see Kunwar v Northwell Health , 229 AD3d 528 , 531). | 3 | 3 |
Sanders v. Guidagreen2 sentences2025"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Sanders v Guida , 213 AD3d 712, 715 [internal quotation marks omitted]; see Kunwar v Northwell Health , 229 AD3d 528 , 531). 2024"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Sanders v Guida , 213 AD3d 712, 715 [internal quotation marks omitted]). | 3 | 3 |
Pirozzi v. Garvingreen2 sentences2026Here, the Louis plaintiffs failed to demonstrate that the relation-back doctrine applied inasmuch as they did not establish that the Uber defendants had knowledge of the claim or occurrence within the applicable limitations period ( see Pirozzi v Garvin , 185 AD3d 848, 851; Flederbach v Fayman , 57 AD3d 474, 475). 2026Here, the Louis plaintiffs failed to demonstrate that the relation-back doctrine applied inasmuch as they did not establish that the Uber defendants had knowledge of the claim or occurrence within the applicable limitations period ( see Pirozzi v Garvin , 185 AD3d 848, 851 ; Flederbach v Fayman , 57 AD3d 474, 475 ). | 1 | 1 |
Lacanfora v. Tullygreen2 sentences2026"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Lacanfora v Tully , 241 AD3d at 669 [internal quotation marks omitted]; see OneWest Bank N.A. v Muller , 189 AD3d at 856). 2026"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Lacanfora v Tully , 241 AD3d at 669 [internal quotation marks omitted]; see OneWest Bank N.A. v Muller , 189 AD3d at 856). | 1 | 1 |
Norton v. County of Westchestergreen2 sentences2026"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Norton v County of Westchester , 241 AD3d 833, 834 [internal quotation marks omitted]; see U.S. Bank N.A. v 1702 Dean, LLC , 240 AD3d 928, 931). 2026"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Norton v County of Westchester , 241 AD3d 833 , 834 [internal quotation marks omitted]; see U.S. Bank N.A. v 1702 Dean, LLC , 240 AD3d 928 , 931). | 1 | 1 |
OneWest Bank N.A. v. Mullergreen2 sentences2026"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Lacanfora v Tully , 241 AD3d at 669 [internal quotation marks omitted]; see OneWest Bank N.A. v Muller , 189 AD3d at 856). 2026"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Lacanfora v Tully , 241 AD3d at 669 [internal quotation marks omitted]; see OneWest Bank N.A. v Muller , 189 AD3d at 856). | 1 | 1 |
Flederbach v. Faymangreen2 sentences2026Here, the Louis plaintiffs failed to demonstrate that the relation-back doctrine applied inasmuch as they did not establish that the Uber defendants had knowledge of the claim or occurrence within the applicable limitations period ( see Pirozzi v Garvin , 185 AD3d 848, 851; Flederbach v Fayman , 57 AD3d 474, 475). 2026Here, the Louis plaintiffs failed to demonstrate that the relation-back doctrine applied inasmuch as they did not establish that the Uber defendants had knowledge of the claim or occurrence within the applicable limitations period ( see Pirozzi v Garvin , 185 AD3d 848, 851 ; Flederbach v Fayman , 57 AD3d 474, 475 ). | 1 | 1 |
Wilson v. Rye Family Realty, LLCgreen1 sentence2025"The linchpin of the relation-back doctrine is whether the new defendant had notice within the applicable limitations period" ( Wilson v Rye Family Realty, LLC , 218 AD3d 836, 838 [internal quotation marks omitted]; see Uddin v A.T.A. | 1 | 1 |
Schiavone v. Fortunered2 sentences2017Auth., 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e (6)]). 2 It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant’s receipt of notice, within the applicable limitations period, of the factual basis for any new claim (see Buran v Coupal, 87 NY2d at 180 , citing Schiavone v Fortune, 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc., 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca, 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh, 61 AD3d 405, 40 2017Auth. , 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e(6)]). [FN2] It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant's receipt of notice, within the applicable limitations period, of the factual basis for any new claim ( see Buran v Coupal , 87 NY2d at 180 , citing Schiavone v Fortune , 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc. , 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca , 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh , 61 AD | 1 | 1 |
Cady v. Springbrook NY, Inc.green2 sentences2017Auth., 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e (6)]). 2 It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant’s receipt of notice, within the applicable limitations period, of the factual basis for any new claim (see Buran v Coupal, 87 NY2d at 180 , citing Schiavone v Fortune, 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc., 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca, 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh, 61 AD3d 405, 40 2017Auth. , 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e(6)]). [FN2] It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant's receipt of notice, within the applicable limitations period, of the factual basis for any new claim ( see Buran v Coupal , 87 NY2d at 180 , citing Schiavone v Fortune , 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc. , 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca , 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh , 61 AD | 1 | 1 |
US Bank National Ass'n v. Gestetnergreen2 sentences2017Auth., 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e (6)]). 2 It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant’s receipt of notice, within the applicable limitations period, of the factual basis for any new claim (see Buran v Coupal, 87 NY2d at 180 , citing Schiavone v Fortune, 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc., 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca, 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh, 61 AD3d 405, 40 2017Auth. , 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e(6)]). [FN2] It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant's receipt of notice, within the applicable limitations period, of the factual basis for any new claim ( see Buran v Coupal , 87 NY2d at 180 , citing Schiavone v Fortune , 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc. , 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca , 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh , 61 AD | 1 | 1 |
Fisher v. Giucagreen2 sentences2017Auth., 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e (6)]). 2 It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant’s receipt of notice, within the applicable limitations period, of the factual basis for any new claim (see Buran v Coupal, 87 NY2d at 180 , citing Schiavone v Fortune, 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc., 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca, 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh, 61 AD3d 405, 40 2017Auth. , 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e(6)]). [FN2] It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant's receipt of notice, within the applicable limitations period, of the factual basis for any new claim ( see Buran v Coupal , 87 NY2d at 180 , citing Schiavone v Fortune , 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc. , 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca , 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh , 61 AD | 1 | 1 |
People v. Tavarezgreen2 sentences2017Auth., 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e (6)]). 2 It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant’s receipt of notice, within the applicable limitations period, of the factual basis for any new claim (see Buran v Coupal, 87 NY2d at 180 , citing Schiavone v Fortune, 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc., 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca, 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh, 61 AD3d 405, 40 2017Auth. , 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e(6)]). [FN2] It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant's receipt of notice, within the applicable limitations period, of the factual basis for any new claim ( see Buran v Coupal , 87 NY2d at 180 , citing Schiavone v Fortune , 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc. , 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca , 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh , 61 AD | 1 | 1 |
Gaspari v. Sadehgreen2 sentences2017Auth., 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e (6)]). 2 It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant’s receipt of notice, within the applicable limitations period, of the factual basis for any new claim (see Buran v Coupal, 87 NY2d at 180 , citing Schiavone v Fortune, 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc., 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca, 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh, 61 AD3d 405, 40 2017Auth. , 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e(6)]). [FN2] It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant's receipt of notice, within the applicable limitations period, of the factual basis for any new claim ( see Buran v Coupal , 87 NY2d at 180 , citing Schiavone v Fortune , 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc. , 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca , 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh , 61 AD | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Brock v. Bua
green
1 sentence2020Here, contrary to the Zanders' contention, the plaintiff established the third prong of the relation-back doctrine, which focuses, among other things, on "whether the defendant could have reasonably concluded that the failure to sue within the limitations period meant that there was no intent to sue that person at all 'and that the matter has been laid to rest as far as he [or she] is concerned'" ( Buran v Coupal , 87 NY2d at 181 [emphasis omitted], quoting Brock v Bua , 83 AD2d 61, 70 ). | 1 | 2020–2020 |
Kirk v. University Ob-Gyn Associates, Inc.
green
2 sentences2017Auth., 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e (6)]). 2 It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant’s receipt of notice, within the applicable limitations period, of the factual basis for any new claim (see Buran v Coupal, 87 NY2d at 180 , citing Schiavone v Fortune, 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc., 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca, 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh, 61 AD3d 405, 40 2017Auth. , 16 AD3d 164, 165 (1st Dept 2005), so holding in a case relying on precedent pertaining to General Municipal Law § 50-e(6)]). [FN2] It is clear, however, that the linchpin of the relation-back exception is universally recognized to be the defendant's receipt of notice, within the applicable limitations period, of the factual basis for any new claim ( see Buran v Coupal , 87 NY2d at 180 , citing Schiavone v Fortune , 477 US 21, 31 [1986]; Kirk v University OB-GYN Assoc., Inc. , 104 AD3d 1192 , 1194 [4th Dept 2013]; Fisher v Giuca , 69 AD3d 671, 672 [2d Dept 2010]; Gaspari v Sadeh , 61 AD | 1 | 2017–2017 |