ERNEST BEATTY and MARY BEATTY v. Sunbeam Corporation

*The Hon. Soloman Oliver, Jr., United States District Judge for the N orthern District of Ohio, sitting
by des ignation.
NOT RECOMMENDED FOR FULL-TEXT PUBLICATION
File Name: 04a0009n.06
Filed: October 6, 2004
Case Nos. 03-1969/1970
UNITED STATES COURT OF APPEALS
FOR THE SIXTH CIRCUIT
ERNEST BEATTY and MARY BEATTY,
Plaintiffs-Appellants,
AMERICAN FELLOWSHIP MUTUAL
INSURANCE COMPANY,
Plaintiff-Appellant,
v.
SUNBEAM CORPORATION,
Defendant-Appellee.
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ON APPEAL FROM THE UNITED
STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF MICHIGAN
Before: NORRIS and DAUGHTREY, Circuit Judges, and OLIVER,* District Judge.
PER CURIAM. The plaintiffs, Ernest and Mary Beatty and the American Fellowship
Mutual Insurance Company, filed products liability actions against Sunbeam Corporation
in April 1999, asserting that a Sunbeam electric blanket caused a fire in the Beattys’ home
in November 1996. The complaints had been consolidated and were ready for trial when,
in 2001, Sunbeam filed voluntary petitions for bankruptcy under Chapter 11 of the United
States Bankruptcy Code, thereby effecting an automatic stay of this litigation. The stay was
lifted in December 2002, and a month later, the plaintiffs moved to amend their complaints

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Nos. 03-1969/1970
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to “add and substitute” Sunbeam Products, Inc., as a defendant. They asserted that they
had discovered that Sunbeam Products, a wholly-owned subsidiary of Sunbeam, was the
actual manufacturer of the blanket. The district court denied their motions to amend,
concluding (1) that granting leave to amend would be futile because the statute of
limitations had run and (2) that the amendments could not relate back, pursuant to Federal
Rule of Civil Procedure 15(c)(3), because the plaintiffs were not seeking to correct a
misnomer but to add a party or to substitute one corporate entity for another.
The plaintiffs appeal, arguing that the district court erred in denying their motions to
amend and dismissing their complaints.
Having had the benefit of oral argument, and having studied the record on appeal
and the briefs of the parties, we are not persuaded that the district court erred in denying
the motions to amend and dismissing the complaints. Because the reasons why judgment
should be entered for the defendant have been fully articulated by the district court, the
issuance of a detailed opinion by this court would be duplicative and would serve no useful
purpose. Accordingly, we AFFIRM the judgment of the district court upon the reasoning
set out by that court in its opinion and order dated June 25, 2003.

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