2. Are supplemental pleadings governed by the same relation back analysis as amended pleadings? One view is reflected in DAVIS v. PIPER AIRCRAFT CORP., 615 F.2d 606, 609 n.3 (4th Cir.1980). In that case, plaintiff moved to amend his complaint pursuant to Rule 15(a)(1)to reflect his new capacity as ancillary administrator of an estate, which allowed him to go forward with a wrongful death action filed nine months earlier. According to the Court of Appeals, if “the test of Fed.R.Civ.P. 15

(c) is met, a supplemental pleading should ordinarily be given the same relation back effect as an amended pleading.” Would relation back be appropriate when the supplementation attempts to allege an entirely different transaction by amendment?