Downing v. Lawrence Hall Nursing Center

This opinion today, which forces the appellants, in effect, to return to the trial court for resolution of claims against John Doe defendants, when the plaintiffs complaint has already been dismissed by the trial court, defies the test of reasonableness. I would treat a dismissed complaint as exactly that — a dismissed complaint — and not require the trial court to engage in a redundant act. To remand to the trial court under these facts is meaningless and further delays resolution of this appeal and justice for the parties.

Clearly, where claims against John Doe defendants have not been…