No Relation Back: District Court Bars Substitution of John Doe Defendants After Statute of Limitations in § 1983 Opiate Withdrawal Death Case

Dovel v. Lancaster Cnty., No. CV 24-0467, 2025 WL 3459601, at *1 (E.D. Pa. Dec. 2, 2025) – The estate of an incarcerated decedent filed a complaint against the correctional facility, the warden of the facility and “John Doe” correctional officers on January 31, 2024. The complaint stemmed from the incarcerated decedent’s February 1, 2022, death due to complications associated with opiate withdrawal. The plaintiff’s claims included a § 1983 claim of deliberate indifference, alleging that the…
By: Marshall Dennehey