Jared Lee Hawkins v. Wellpath Liquidating Trust; Jane Doe; and Kelly Doe

CourtDistrict Court, D. Oregon
DecidedFebruary 27, 2026
Docket6:23-cv-01968
StatusUnknown

This text of Jared Lee Hawkins v. Wellpath Liquidating Trust; Jane Doe; and Kelly Doe (Jared Lee Hawkins v. Wellpath Liquidating Trust; Jane Doe; and Kelly Doe) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jared Lee Hawkins v. Wellpath Liquidating Trust; Jane Doe; and Kelly Doe, (D. Or. 2026).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

JARED LEE HAWKINS, Case No.: 6:23-cv-01968-JR

Plaintiff,

v. ORDER

WELLPATH LIQUIDATING TRUST; JANE DOE; and KELLY DOE,1

Defendants.

Adrienne Nelson, District Judge: United States Magistrate Jolie A. Russo issued Findings and Recommendations (“F&R”) in this case on July 8, 2025, recommending that plaintiff Jared Lee Hawkins’ motion to amend should be denied as to the proposed 42 U.S.C. § 1983 claim against Douglas County and granted in all other respects. On July 22, 2025, defendant Wellpath LLC filed objections to the F&R. On February 6, 2026, Judge Russo dismissed Wellpath LLC from the case pursuant to its ongoing bankruptcy proceedings and substituted nominal defendant Wellpath Liquidating Trust in its place. Now that the issue of Wellpath LLC’s status in the case has been resolved, this Court addresses the outstanding F&R. For the reasons described below, the Court adopts the F&R in full, and grants in part and denies in part plaintiff’s motion for leave to file a third amended complaint. LEGAL STANDARD A district court judge may “accept, reject, or modify, in whole or in part, the findings or recommendations made by the magistrate judge.” 28 U.S.C. § 636(b)(l). When a magistrate judge issues a findings and recommendation report, and a party files objections, “the court shall make a de novo

1 As discussed in the following Order, nominal defendant Wellpath LLC was substituted for nominal defendant Wellpath Liquidating Trust on February 6, 2026. See Order of February 6, 2026, ECF 66. determination of those portions of the report.” Id. No specific standard of review is required in the absence of objections. Thomas v. Arn, 474 U.S. 140, 152-54 (1985). However, the Advisory Committee notes to Federal Rule of Civil Procedure 72(b) recommend that unobjected to proposed findings and recommendations be reviewed for “clear error on the face of the record.” Fed. R. Civ. P. 72(b) advisory committee’s note to 1983 amendment. DISCUSSION The F&R concerns plaintiff’s motion for leave to file a third amended complaint. Plaintiff seeks amendment for three primary purposes: (1) to identify the Doe defendants by name; (2) to add Douglas County as a defendant to plaintiff’s state law negligence claims; and (3) to add Douglas County as a defendant to plaintiff’s Section 1983 claim. F&R, ECF 48, at 4. The F&R recommends granting plaintiff’s request as to identifying the Doe defendants and adding Douglas County as a defendant to the state law negligence claims but denying the request as to adding Douglas County as a defendant to the Section 1983 claim. Id. at 10. A. Review of the F&R Wellpath LLC filed objections to the F&R, arguing that the statute of limitations bars plaintiff from amending to allege the Doe defendants’ identities because claims against the now-named defendants cannot relate back to the second amended complaint. Wellpath LLC Objs., ECF 50, at 2. Wellpath LLC did not object to the portions of the F&R concerning Douglas County, and no other party filed objections. Wellpath LLC has since been dismissed from the case. See Order of February 6, 2026, ECF 66. Typically, a party’s dismissal would moot its outstanding objections. See Council of Ins. Agents & Brokers v. Molasky-Arman, 522 F.3d 925, 933 (9th Cir. 2008) (“A claim is moot when the issues presented are no longer live or the parties lack a legally cognizable interest in the outcome. The basic question is whether there exists a present controversy as to which effective relief can be granted.” (quoting Outdoor Media Group, Inc. v. City of Beaumont, 506 F.3d 895, 900 (9th Cir. 2007))). Nonetheless, the Court’s review of the F&R does not depend on the objections because district judges are permitted to sua sponte conduct further review “under a de novo or any other standard.” Thomas, 474 U.S. 140 at 154. In light of that, and recognizing that Wellpath’s objections primarily concern the two individual defendants, the Court undertakes a de novo review of the objected-to portions of the F&R concerning the Doe defendants’ identities and whether the claims against them relate back to the second amended complaint. B. Relation Back It is undisputed that the claims against the individual defendants may only survive if they relate back to the second amended complaint. See Sain v. City of Bend, 309 F.3d 1134, 1139 (9th Cir. 2004). It is also undisputed that the claims may only survive if they relate back under Oregon state law. See Butler v. Nat’l Cmty. Renaissance of Cal., 766 F.3d 1191, 1199-1201 (9th Cir. 2014) (directing federal courts to use the “more permissive” of the federal and state standards (quotation marks and citations omitted)); see also Boss v. City of Mesa, 746 F. App’x 692, 695 (9th Cir. 2018) (“Replacing a ‘John Doe’ defendant with the actual name of a defendant is not a ‘mistake’ that allows relation back under [Federal Rule of Civil Procedure] 15(c)(1)(C).”). The only dispute is whether Oregon law allows plaintiff to relate his claims against the now-named defendants back to the claims he pleaded against the Doe defendants in his earlier complaint. Courts within this District have split on this issue. 1. Relation Back Under Oregon Law a. Relation Back to Mistaken Identities Under Oregon Law Relation back under Oregon law is governed by Oregon Rule of Civil Procedure (“ORCP”) 23C: Whenever the claim or defense 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 amendment relates back to the date of the original pleading. An amendment changing the party against whom a claim is asserted relates back if the foregoing provision is satisfied and, within the period provided by law for commencing the action against the party to be brought in by amendment, such party (1) has received such notice of the institution of the action that the party will not be prejudiced in maintaining any defense on the merits, and (2) knew or should have known that, but for a mistake concerning the identity of the proper party, the action would have been brought against the party brought in by amendment.

Or. R. Civ. P. 23C. As to the “mistake” requirement, Oregon courts distinguish between two “types of cases”: one, cases where the plaintiff makes “a mistake in choosing which person or entity to sue—a ‘misidentification’”; and two, cases where the plaintiff makes “a mistake in naming that person or entity, that is, an error in stating what the defendant is called—a ‘misnomer.’” Worthington v. Est. of Davis, 250 Or. App. 755, 760, 282 P.3d 895 (2012) (emphases in original). The notice requirement applies only to misidentified defendants. Id.

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Related

Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Outdoor Media Group, Inc. v. City of Beaumont
506 F.3d 895 (Ninth Circuit, 2007)
Harmon v. Meyer
933 P.2d 361 (Court of Appeals of Oregon, 1997)
Clavette v. Sweeney
132 F. Supp. 2d 864 (D. Oregon, 2001)
Zina Butler v. Housing Auth. County of La
766 F.3d 1191 (Ninth Circuit, 2014)
Worthington v. Estate of Davis
282 P.3d 895 (Court of Appeals of Oregon, 2012)
Vergara v. Patel
471 P.3d 141 (Court of Appeals of Oregon, 2020)
Lemus v. Potter
498 P.3d 1 (Court of Appeals of Oregon, 2021)

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Jared Lee Hawkins v. Wellpath Liquidating Trust; Jane Doe; and Kelly Doe, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jared-lee-hawkins-v-wellpath-liquidating-trust-jane-doe-and-kelly-doe-ord-2026.