Santiago v. E.W. Bliss Co., 2012 IL 111792
Aug 09, 2012OUTCOME: Plaintiff's complaint at law filed under fictitious name without leave of court was not per se null and void, such that amended complaint filed under plaintiff's legal name could not relate back for statute of limitations purposes.
The issue considered was whether a plaintiff's tort claim was subject to dismissal as a sanction for filing a complaint using an alias without leave of court and whether that dismissal should be with p ... rejudice because an amended complaint with the plaintiff's birth name did not relate back to the initial filing.
