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Keywords

settlementplaintiffdefendantattorneystatutemotionstatute of limitationsgood faithmotion to dismiss

plaintiffdefendantattorneystatutestatute of limitationsgood faith

Related Cases

Archuleta v. City of Rawlins, 942 P.2d 404

Facts

Archuleta was injured in an automobile accident when her car was rear-ended by a vehicle operated by a city employee. Under the Wyoming Governmental Claims Act, Archuleta filed a claim with the city manager on April 7, 1994, but had no further contact until early 1995. The City Attorney requested delays in filing a complaint, but ultimately informed Archuleta's counsel that the insurance company would not make a settlement offer just after the statute of limitations had expired. Archuleta then filed her complaint, leading to the city's motion to dismiss based on the statute of limitations.

Archuleta was injured in an automobile accident when her car was rear-ended by a vehicle operated by a city employee in the employee's course of employment. The Wyoming Governmental Claims Act, § 113, requires an injured party to present a claim to the government entity within two years; § 114 bars actions against a government entity unless the claimant commences an action within one year after the date the claim is filed.

Issue

Can the Doctrine of Equitable Estoppel be asserted as a bar to the Statute of Limitations contained in the Wyoming Governmental Claims Act?

Rule

In order to establish equitable estoppel, the delay in filing the action must be induced by the defendant; the defendant must have misled the plaintiff; and the plaintiff must have acted on the misinformation in good faith.

In order to establish equitable estoppel, “[t]he delay in filing the action must be induced by the defendant; the defendant must have misled the plaintiff; and the plaintiff must have acted on the misinformation in good faith to the extent that he failed to pursue his action in a timely manner.”

Analysis

The court found that while Archuleta may have been induced by the City Attorney's request for delay, there was no evidence that the City Attorney misled her or concealed facts to her detriment. The requests for delay were based on the City Attorney's failure to review the claim, and he did not possess superior knowledge of the facts necessary for Archuleta's claim. Therefore, the elements required for equitable estoppel were not met.

The facts in this case are insufficient to establish estoppel because, while Archuleta may have been induced by the City Attorney's request for delay in filing, the City Attorney in no way misled Archuleta or concealed facts to her detriment.

Conclusion

The court affirmed the district court's decision, concluding that the facts did not establish a basis for equitable estoppel against the statute of limitations defense.

Affirmed.

Who won?

City of Rawlins prevailed because the court found that the elements of equitable estoppel were not satisfied, as the city did not mislead Archuleta.

The district court found that the facts of this case did not meet the elements of equitable estoppel and that no basis existed for applying equitable estoppel to the governmental claims act.

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