Coronet Manufacturing Co. v. Superior Court

In Coronet Manufacturing Co. v. Superior Court (1979) 90 Cal.App.3d 342, the initial complaint alleged electrocution due to a defective hair dryer and the amended complaint asserted electrocution by a switch on the table lamp. (Id. at p. 347.) The court concluded that these were different accidents but noted that the relation-back doctrine could possibly apply if the plaintiff could allege that the hair dryer was connected to the lamp's switch and socket. If such facts could be alleged, the amended complaint would be referring to the same accident, i.e., use of the hair dryer and its components and would be based on the same general set of facts. (Id. at pp. 347-348.)