A transit officer cannot escape a lawsuit just because he was identified late.
Damon B Wilson v. Washington Metropolitan Area Transit Authority, et al.
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A transit officer cannot escape a lawsuit just because he was identified late.
Why it matters
In Wilson v. Washington Metropolitan Area Transit Authority et al., a federal district court in Maryland denied Metro Officer Lyndon Harris's motion to dismiss an assault claim against him. The court found that Wilson's amended complaint adding Harris as a defendant related back to the original, timely filed complaint under Federal Rule of Civil Procedure 15(c), meaning the claim was not barred by Maryland's one-year statute of limitations for assault. The court also granted Wilson's motion for an extension of time and denied two other pending motions as moot.
Who it affects
This ruling most directly affects Damon Wilson as the plaintiff and Metro Officer Lyndon Harris as a defendant in this civil rights and assault case. More broadly, it is relevant to transit riders who may suffer alleged misconduct by transit authority officers and face challenges identifying specific officers before a legal deadline expires.
What happens next
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Decision issued Oct 13, 2026
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- Decision issued Oct 13, 2026
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- Possible appeal to the circuit court
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Oct 13, 2026
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The central question was whether an assault claim against a newly added defendant was too late under Maryland's one-year statute of limitations for assault. Officer Harris argued that because Wilson did not name or serve him until more than two and a half years after the underlying incident, the claim was time-barred. Wilson responded that his amended complaint should be treated as filed on the same date as his original complaint, a legal concept called 'relation back' under Federal Rule of Civil Procedure 15(c). The court sided with Wilson. Under Rule 15(c), an amended complaint relates back to the original filing date when the new claim arises from the same conduct described in the original complaint, and when the newly added party had notice of the lawsuit and knew or should have known they would have been named but for a mistake about identity. Here, the court found that the amended complaint concerned the very same incident described originally, namely officers removing Wilson from a WMATA bus over an unpaid fare, during which Harris allegedly shoved Wilson and caused physical injury. Harris also had notice of the suit. Harris made two additional arguments that the court rejected. First, he incorrectly argued that the one-year clock runs from when he was served, not from when the original complaint was filed. The court clarified that limitations are measured from when the action is filed, not when a defendant is served. Second, Harris argued that Wilson waited too long to identify him. The court noted that Wilson had tried to find Harris's identity but WMATA refused to help without a court order, and the court had eventually ordered WMATA to disclose the names of officers involved. The court also noted that a statute of limitations defense is generally not resolved at the dismissal stage unless the bar is clearly visible on the face of the complaint itself, which was not the case here. Because the amended complaint plausibly related back to the original filing, the court denied the motion to dismiss. The court also found it unnecessary to consider exhibits attached to the briefing, denied the motion to strike those exhibits as moot, denied a motion for a scheduling order as moot because a new scheduling order would be issued separately, and granted Wilson's unopposed request for an extension of time.
CITATION AND RECORD
Record source: CourtListener
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND * DAMON B. WILSON, * Plaintiff, * v. * Civ. No. 8:25-cv-1312-PX WASHINGTON METROPOLITAN AREA TRANSIT AUTHORITY et al., * Defendants. * *** MEMORANDUM OPINION Pending in this civil rights action are several motions filed by Plaintiff Damon B. Wilson (“Wilson”) and Defendant Metro Officer Lyndon Harris (“Harris”). ECF Nos. 46, 48, 49, & 53. Harris moves for dismissal from this action, ECF No. 48, and Wilson moves for the issuance of a scheduling order, ECF No. 46;1 for an extension of time, ECF No. 49;2 and to strike attachments to Harris’s reply in support of his dismissal motion, ECF No. 53. The issues are fully briefed, and no hearing is necessary. See D. Md. Loc. R. 105.6. For the following reasons, the motion to dismiss is denied, ECF No. 48; the motion for a scheduling order is denied as moot, ECF No. 46; the motion for extension of time is granted, ECF No. 49; and the motion to strike is denied as moot, ECF No. 53. I. Background This Opinion incorporates the facts and procedural history as described in the Court’s previous Memorandum Opinion at ECF No. 39. Since then, Wilson has filed his Fourth Amended 1 A scheduling order will follow this opinion and the accompanying order resolving the motion to dismiss. Because the proposed scheduling order is now outdated, the motion is denied as moot. ECF No. 46. 2 Defendants do not oppose Wilson’s motion for extension of time, and they will not be prejudiced by the requested extension. ECF No. 29. Complaint, adding Harris as a Defendant. ECF No. 41. Defendant Washington Metropolitan Area Transit Authority (“WMATA”) answered, ECF No. 43, and Harris now moves to dismiss the assault claim against him, ECF No. 48. For the following reasons, his motion is denied. II. Standard of Review A motion to dismiss brought pursuant to Rule 12(b)(6) tests the sufficiency of the complaint. See Presley v. City of Charlottesville, 464 F.3d 480, 483 (4th Cir. 2006). The Court must accept “the well-pled allegations of the complaint as true” and most favorably to the nonmovant. Ibarra v. United States, 120 F.3d 472, 474 (4th Cir. 1997). To survive a motion to dismiss, a complaint’s factual allegations “must be enough to raise a right to relief above the speculative level . . . on the assumption that all the allegations in the complaint are true (even if doubtful in fact).” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) (citations omitted). The Court, however, need not credit naked legal conclusions devoid of factual support. See Ashcroft v. Iqbal, 556 U.S. 662, 678–79 (2009). Rather, a complaint’s factual allegations “must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. III. Analysis Harris singularly argues that the assault claim is barred by limitations. ECF No. 48-1 at 2. Maryland law provides that “[a]n action for assault . . . shall be filed within one year from the date it accrues.” Md. Cts. & Jud. Proc. § 5-105. Wilson, as Harris correctly points out, amended his complaint to add Harris as a defendant more than two and a half years after the underlying incident occurred. ECF No. 48-1 at 2. Wilson responds that amendment is timely pursuant to Federal Rule of Civil Procedure 15(c) because it relates back to the original, timely filed, complaint. ECF No. 50 at 7. Rule 15(c) provides that an amended pleading “relates back to the date of the original pleading when . . . the amendment asserts a claim or defense that arose out of the conduct, transaction, or occurrence set out—or attempted to be set out—in the original pleading.” Fed. R. Civ. P. 15(c)(1). New parties may be added under Rule 15(c) where “the party to be brought in by amendment: (i) received such notice of the action that it will not be prejudiced in defending on the merits; and (ii) knew or should have known that the action would have been brought against it, but for a mistake concerning the proper party’s identity.” Id. 15(c)(1)(C). That is this. The matter concerns a single incident where officers, including Harris, demanded that Wilson leave the WMATA bus for failing to pay the fare, and Harris shoved Wilson from behind, causing physical injury. ECF No. 50 at 1. The parties also do not dispute that Harris had notice of the suit. Instead, Harris mistakenly argues that limitations are keyed to service of the complaint, and from there, argues that late service as to him renders the claim time barred. ECF No. 52 at 3. Not so. If a claim is filed within one year of the incident, it is timely. Md. Cts. & Jud. Proc. § 5-105 (emphasis added); see ECF No. 52 at 3. Harris next argues that under Rule 15(c), Wilson cannot add him because Wilson’s attempts to learn Harris’s identity were too little too late. No. 52 at 4. The Court disagrees. Wilson tried to ascertain Harris’s identity despite WMATA’s refusal—absent court order—to assist in that regard. See ECF No. 18 (ordering WMATA to produce relevant incident reports and identities of all involved officers). In any event, the timeliness of an action remains an affirmative defense not generally amenable to resolution at the dismissal stage. See Goodman v. Praxair, Inc., 494 F.3d 458, 464 (4th Cir. 2007). And limitations will not doom a claim unless “all facts necessary to the affirmative defense ‘clearly appear[] on the face of the complaint.’” Id. (emphasis omitted) (quoting Richmond, Fredericksburg & Potomac R.R. Co. v. Forst, 4 F.3d 244, 250 (4th Cir. 1993)). But here, when viewing the amended pleading most favorably to Wilson, the claim plausibly relates back to the original complaint, and so will not be dismissed on limitations grounds. In so deciding, the Court need not consider any exhibits attached to either party’s briefing on the motion to dismiss. See ECF Nos. 53 & 54. With or without these submissions, Wilson has the better of the argument. Therefore, the motion to strike at ECF No. 53 is denied as moot. IV. Conclusion For the reasons discussed, the motion to dismiss is denied (ECF No. 48), the motion for a scheduling order is denied as moot (ECF No. 46), the motion for extension of time is granted (ECF No. 49), and the motion to strike is denied as moot (ECF No. 53). A separate order follows. 10/13/2026 /s/ Date Paula Xinis United States District Judge
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