Reported / Citable
Background
Marc Steven Luxemburg sued Citibank, N.A., Rausch Sturm, LLP, Matthew Wayne Cooper, and Samantha Gallivan over a debt-collection matter. He moved for leave to amend his complaint to add claims under the Fair Debt Collection Practices Act.
The proposed claims arose, at the earliest, when Luxemburg contacted the defendants on December 16, 2024, to dispute the collection action. He filed his original complaint on December 16, 2025. Defendants had also moved to dismiss for failure to state a claim.
The Court’s Holding
Judge Leon Schydlower granted Luxemburg leave to file the amended complaint. The court held that the new FDCPA claims arose from the conduct, transaction, or occurrence set out in the original pleading and therefore related back under Federal Rule of Civil Procedure 15(c)(1)(B).
Because the original complaint was filed within the FDCPA’s one-year limitations period, the relation-back doctrine meant the proposed claims were not time-barred. The court denied defendants’ pending motion to dismiss as moot, while permitting them to renew it.
Key Takeaways
- FDCPA claims added by amendment may relate back when they arise from the same conduct described in the original complaint.
- The court treated December 16, 2024, as the earliest accrual date identified in the order.
- A dismissal motion directed to a superseded complaint may be denied as moot, with leave to renew after amendment.
Why It Matters
The order applies Rule 15’s relation-back doctrine to preserve FDCPA claims added after the limitations period where the original timely pleading supplied the same operative factual basis. It also reflects the preference for resolving related claims on their merits when defendants had notice of the underlying transaction or occurrence.