The relation back component of Federal Rule of Civil Procedure 15(c) is like a sword of Damocles. Whether a plaintiff in good faith can file an amended complaint pursuant to Rule 15(c), which relates back to the time before the statute of limitations expired, can be the difference between the “life and death” for an action of malpractice versus a good night’s sleep and no worries for the filling attorney.

Moore v. Walton, 2024 U.S. App. LEXIS 6713 (3rd Cir. March 21, 2024) (Scirica, C.J.) (unpublished opinion), attempted to tackle the relation back doctrine and what is meant by “good cause.” The specific issue is whether Federal Rule of Civil Procedure 15(c)(1)(C)’s reference to “the period provided by Rule 4(m)” includes any “good cause” extensions granted under that rule.