In Crowe v. Houseworth, 272 Md. 481, 485, 325 A.2d 592 (1974), the Court addressed an amended complaint in which the plaintiff, a joint tenant, sought to add other joint tenants as parties. In discussing "the increased liberality with which amendments of pleadings may be allowed," 272 Md. at 485, the Court commented that, with respect to the doctrine of relation back; "The modern view seems to be that so long as the operative factual situation remains essentially the same, no new cause of action is stated by a declaration framed on a new theory or invoking different legal principles. As a consequence, the doctrine of relation back is applied, and the intervention of a plea of limitations prevented." 272 Md. at 485-86. In Crowe v. Houseworth, one of several joint tenants owning property sued the defendant, alleging trespass. The defense raised the point that all joint tenants had to join in the action. The joinder was permitted, and it related back to the filing of the complaint for purposes of limitations. 272 Md. at 489. The Court emphasized that there was no prejudice to the defendant. 272 Md. at 485, 489. The Court of Appeals held that a circuit court abused its discretion by denying a plaintiff's request to join certain co-plaintiffs as necessary parties after the expiration of the statute of limitations. Id. at 489. In that case, Crowe brought an action for trespass to real property (id. at 483), but the circuit court entered judgment against him on the ground that he owned the property jointly with eleven others whom he could not join because the statute of limitations had expired. On review, the Court of Appeals agreed that Crowe could not prosecute the action without joining the other joint tenants as parties. Id. Nevertheless, the Court observed that Crowe himself had filed suit within the limitations period and that the joinder of the additional parties would affect "neither the gravamen of the action nor the measure of damages." Id. at 485. The Court adopted the modern view that the doctrine of relation back should prevent the defendant, Houseworth, from invoking the statute of limitations to bar the joinder of the additional parties. Id. at 485-86. The Court explained: "'when a defendant has had notice from the beginning that the plaintiff sets up and is trying to enforce a claim against it because of specified conduct, the reasons for the statute of limitations do not exist, and we are of the opinion that a liberal rule should be applied.'" Id. at 489.