Snow v. Warren Power & Mach., Inc.

Ken Snow worked as an operator for the Navajo Refinery. During a procedure called a "turn-around" at the refinery, a hose assembly came loose and struck Snow, causing "serious, life-changing injuries." Snow and his wife filed suit against the Refinery, complaining of personal injury, loss of consortium, and asked for punitive damages. Snow named as defendants Midwest Hose & Specialty, Inc., Gandy Corporation, Repcon, Inc., and Holly Corporation as defendants. After a period of discovery, Snow sought to amend his complaint to add Warren Power & Machinery, Inc. d/b/a Warren CAT and Brininstool Equipment Sales. What this case presented for the Supreme Court's review centered on the "unusual" issue dealing with the procedure for seeking leave to amend a complaint to add parties as additional defendants. When the motion for leave is filed before the statute of limitations has run, but the order granting leave is filed after the statute has run, is the amended complaint time barred? Adopting a new rule for this situation, the Court held that the subsequently filed amended complaint, post-statute of limitations, was deemed filed as of the date of the original motion for leave to file and accordingly, the statute of limitations was not a bar. The Court of Appeals held to the contrary, and the Supreme Court reversed. View "Snow v. Warren Power & Mach., Inc." on Justia Law