Lettie Preston and Rodena Preston, Co-Personal Representatives of the Estate of William Everett Preston

Summary

The court held that Arizona Rule of Civil Procedure 17(a) does not require a plaintiff to prove that the failure to name the real party in interest resulted from an understandable mistake or difficulty in identifying that party before ratification, joinder, or substitution may occur. Because the rule's text permits substitution after a reasonable opportunity following an objection, the superior court erred by dismissing the action on the ground that the personal representatives knew of the bankruptcy. The court affirmed the court of appeals and remanded for further proceedings.