American Annuity Group v. Guaranty Reassurance Corp. Liquidating Trust
Docket: No. 01-3526
Court: Court of Appeals for the Sixth Circuit; January 6, 2003; Federal Appellate Court
Defendant-Appellant Guaranty Reassurance Corporation Liquidating Trust (the "Trust") appeals a summary judgment favoring Plaintiffs-Appellees American Annuity Group and Great American Life Insurance Corporation (collectively “GALIC”). The Trust argues that its counterclaim is timely because it relates back to the original complaint. However, based on the precedent set in Stoner v. Terranella, the court finds that the counterclaim does not relate back, rendering it untimely. The background involves a 1994 contract dispute between GALIC and Guaranty Reassurance Corporation (GRC) over stock purchase terms, leading to litigation initiated by GALIC in 1995. After several judicial proceedings, GRC filed an amended counterclaim in 2001, which GALIC contested as untimely. The court confirmed that under Florida law, equitable actions based on unilateral mistake have a five-year statute of limitations, and the Trust's counterclaim was filed six years post-contract. The court emphasized that the relation back of counterclaims is governed by federal procedural law, not state law, reaffirming that amendments under Rule 13(f) do not relate back, aligning with the Stoner ruling. The Trust's assertion that the counterclaim related back was thus rejected, leading to the affirmation of the district court's summary judgment. The Trust’s request to overturn Stoner is also denied, as the conditions for such action are not met. The court concluded by affirming the district court’s decision.