Donnelly v. Yellow Freight System, Inc

In Donnelly v. Yellow Freight System, Inc., 874 F.2d 402 (7th Cir. 1989), the Court of Appeals for the Seventh Circuit held, inter alia, that, under Federal Rule of Civil Procedure 15(c), the plaintiff's amended complaint, filed in federal court and asserting Title VII violations, related back to her original complaint, filed in an Illinois state court and alleging violations of that state's employment discrimination statute. Federal Rule 15(c) expressly addresses the relation back doctrine. It states, in pertinent part, that "an amendment of a pleading relates back to the date of the original pleading when. . . . the claim . . . . asserted in the amended pleading arose out of the conduct, transaction, or occurrence set forth or attempted to be set forth in the original pleading." The court in Donnelly explained that, even though the original state court claim had been dismissed with prejudice before the amended complaint was filed in federal court, the relation back doctrine still applied. It observed that, under the doctrine of res judicata, the federal court complaint alleging Title VII violations would have been barred because the original state court complaint alleging violations of the state court employment discrimination statute had been dismissed with prejudice.