What is the test for an amended pleading in a motor vehicle accident case?

Generally, an amended complaint will "relate back" to the filing of the original complaint if two elements exist. They are: (1) the amended complaint rests upon the same general set of facts as the original complaint; and (2) it refers to the same accident and same injuries referred to in the original complaint. Smeltzley v. Nicholson Mfg. Co. (1977) 18 Cal.3d 932, 936-937, 136 Cal.Rptr. 269, 559 P.2d 624.)

In essence, in order to "relate back", the amendment must allege the same operative facts and must substitute the name of the new defendant for a previously named Doe defendant. (Lesko v. Superior Court (1982) 127 Cal.App.3d 476, 482, 179 Cal.Rptr. 595.) If these elements are not met, the amending pleading does not "relate back."