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September 19, 2017

Plaintiffs do not always know the names of all defendants when the complaint is filed. They name “John Doe,” hoping to amend when the defendants become known. In Heglund v. City of Grand Rapids, No. 16-3063 (8th Cir. Sept. 7, 2017), Jennifer Heglund and her husband sued cities and counties, state officials, and hundreds of John and Jane Does, alleging that officers had improperly accessed their private information in a driver’s license database. They amended their complaint to replace a John Doe with a former assistant chief of police. The district court granted summary judgment on the ground that the claim was barred by the statute of limitations. The...

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