relation-back doctrine (Montana) · Go Syfert
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relation-back doctrine in Montana

8 Montana opinions name it 1 courts 1929–2026 1 in the last five years

The cases below were cited by Montana 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.

Followed or applied (3)

CaseFollowedCited
Rozan v. Rosengreen
mont · 1967 · cited in 2 Montana opinions naming this issue, 1980–2026
2 sentences

2026See Rierson v. State, 188 Mont. 522, 525-28 , 614 P.2d 1020, 1022-24 (1980) (citing Rozan, 150 Mont. at 124-25 , 431 P.2d at 871 ). ¶54 In fact, “the concept of notice is critical to operation of the relation back rule.” Rierson, 188 Mont. at 528 , 614 P.2d at 1024 .

2026See Rierson v. State, 188 Mont. 522, 525-28 , 614 P.2d 1020, 1022-24 (1980) (citing Rozan, 150 Mont. at 124-25 , 431 P.2d at 871 ). ¶54 In fact, “the concept of notice is critical to operation of the relation back rule.” Rierson, 188 Mont. at 528 , 614 P.2d at 1024 .

12
Rierson v. Stategreen
mont · 1980 · cited in 1 Montana opinions naming this issue, 2026–2026
2 sentences

2026See Rierson v. State, 188 Mont. 522, 525-28 , 614 P.2d 1020, 1022-24 (1980) (citing Rozan, 150 Mont. at 124-25 , 431 P.2d at 871 ). ¶54 In fact, “the concept of notice is critical to operation of the relation back rule.” Rierson, 188 Mont. at 528 , 614 P.2d at 1024 .

2026See Rierson v. State, 188 Mont. 522, 525-28 , 614 P.2d 1020, 1022-24 (1980) (citing Rozan, 150 Mont. at 124-25 , 431 P.2d at 871 ). ¶54 In fact, “the concept of notice is critical to operation of the relation back rule.” Rierson, 188 Mont. at 528 , 614 P.2d at 1024 .

11
Priest v. Taylorgreen
mont · 1987 · cited in 1 Montana opinions naming this issue, 1990–1990
2 sentences

1990See also Priest v. Taylor (1987), 227 Mont. 370 , 740 P.2d 648 .

1990See also Priest v. Taylor (1987), 227 Mont. 370 , 740 P.2d 648 .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Montana. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Ritland v. Rowe green
mont · 1993
2 sentences

1994In addition, without regard to the relation-back doctrine, Fitzgerald’s claim was timely pursuant to our decision in Ritland v. Rowe (1993), 260 Mont. 453 , 861 P.2d 175 .

1994In addition, without regard to the relation-back doctrine, Fitzgerald’s claim was timely pursuant to our decision in Ritland v. Rowe (1993), 260 Mont. 453 , 861 P.2d 175 .

11994–1994
Tynes v. Bankers Life Co. green
mont · 1986
2 sentences

1990Freed urges that the relation back doctrine of Rule 15(c), M.R.Civ.R, as interpreted by this Court in Tynes v. Bankers Life Co. (1986), 224 Mont. 350 , 730 P.2d 1115 , applies.

1990Freed urges that the relation back doctrine of Rule 15(c), M.R.Civ.R, as interpreted by this Court in Tynes v. Bankers Life Co. (1986), 224 Mont. 350 , 730 P.2d 1115 , applies.

11990–1990
LaForest v. Texaco, Inc. green
mont · 1978
2 sentences

1986The District Court, relying on LaForest v. Texaco, Inc. (1978), 179 Mont. 42 , 585 P.2d 1318 , granted the motion, reasoning the relation back rule did not apply.

1986The District Court, relying on LaForest v. Texaco, Inc. (1978), 179 Mont. 42 , 585 P.2d 1318 , granted the motion, reasoning the relation back rule did not apply.

11986–1986
Barrington v. A. H. Robins Co. green
cal · 1985
2 sentences

1985Robbins Co. (Cal. 1985), 39 Cal.3d 146 , 216 Cal.Rptr. 405, at 407 , 702 P.2d 563, at 565 , where it said: “The relation-back doctrine has been used to determine the time of commencement of an action for the purpose of the statute of limitations.

1985Robbins Co. (Cal. 1985), 39 Cal.3d 146 , 216 Cal.Rptr. 405, at 407 , 702 P.2d 563, at 565 , where it said: “The relation-back doctrine has been used to determine the time of commencement of an action for the purpose of the statute of limitations.

11985–1985
Austin v. Massachusetts Bonding & Insurance green
cal · 1961
2 sentences

1985Normally, the statute of limitations commences to run regardless of the injured party’s ignorance of his or her cause of action. (citing authority) In Austin v. Massachusetts Bonding & Insurance Co. (1961) 56 Cal.2d 596 , 15 Cal.Rptr. 817 , 364 P.2d 681 , we held that an amended complaint is not barred by the statute of limitations, even though it substitutes a named party for a fictitious defendant, if the amended complaint relates back to a timely original complaint.

1985Normally, the statute of limitations commences to run regardless of the injured party’s ignorance of his or her cause of action. (citing authority) In Austin v. Massachusetts Bonding & Insurance Co. (1961) 56 Cal.2d 596 , 15 Cal.Rptr. 817 , 364 P.2d 681 , we held that an amended complaint is not barred by the statute of limitations, even though it substitutes a named party for a fictitious defendant, if the amended complaint relates back to a timely original complaint.

11985–1985
Baker v. Ferguson Research, Inc. neutral
mtd · 1974
1 sentence

1978In Baker v. Ferguson Research, Inc. (D.Mont.1974), 61 F.R.D. 637 , plaintiff initially sued Western Land Roller Company, whom he thought to be the manufacturer of a snow scraper that caused plaintiff’s injury.

11978–1978
Murray v. Tingley green
· 1897
2 sentences

1929(Murray v. Tingley, 20 Mont. 260 , 50 Pac. 723 .) The instrument, the recorded notice of appropriation, is an essential step in the acquisition of the water right, and without it the owners of the completed right are not granted the right to relate back the life of their appropriation to the date of posting their notice.

1929(Murray v. Tingley, 20 Mont. 260 , 50 Pac. 723 .) The instrument, the recorded notice of appropriation, is an essential step in the acquisition of the water right, and without it the owners of the completed right are not granted the right to relate back the life of their appropriation to the date of posting their notice.

11929–1929

Statutes the citing opinions construe

MT § Mont. Code Ann. § 25-5-103 (3) MT § Mont. Code Ann. § 27-2-204 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 429 (1929–2026) CA 143 (1965–2025) IL 123 (1962–2026) TX 95 (1958–2025) AL 73 (1984–2026) MI 67 (1977–2026) FL 59 (1961–2025) CT 56 (1988–2023) NC 40 (1971–2025) IA 36 (1992–2026) MD 27 (1962–2022) ID 26 (1984–2018) MS 22 (1987–2018) NJ 22 (1975–2025) CO 18 (1966–2016) LA 18 (1985–2023) PA 17 (1971–2025) OK 16 (1964–2017) UT 16 (1925–2025) GA 16 (1933–2026) MA 15 (1961–2020) MO 15 (1977–2023) OH 14 (1962–2024) WA 13 (1978–2021) IN 12 (1990–2026) TN 12 (1994–2026) MN 9 (1985–2012) DE 9 (1997–2025) NE 8 (1994–2023) MT 8 (1929–2026) AK 8 (1985–2021) OR 7 (1964–2016) NM 7 (1981–2013) AZ 6 (1981–2016) SD 6 (1994–2018) KY 6 (2005–2026) AR 6 (2003–2025) NV 6 (1993–2016) WY 6 (2004–2021) VA 5 (2003–2026) KS 5 (1977–2018) DC 4 (1977–2019) WV 4 (1990–2020) VT 3 (2006–2026) WI 3 (2010–2016) VI 3 (2012–2015) RI 3 (1995–2010) ND 2 (2004–2004) HI 2 (2005–2006)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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