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Keywords

lawsuitplaintiffdefendantliabilitystatutepleastatute of limitationscommon law
lawsuitplaintiffdefendantliabilitystatutestatute of limitationsstatutory interpretation

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Estate of Brice v. Toyota Motor Corp., 373 P.3d 977, 2016-NMSC-018

Facts

Alice Brice died in a car accident on September 13, 2006, when her 2002 Toyota Camry unexpectedly accelerated and collided with a tractor-trailer. The Estate of Alice C. Brice filed a wrongful death lawsuit on August 31, 2010, against the car manufacturer and dealer, alleging products liability and other claims. The lawsuit was filed nearly four years after the accident, prompting the defendants to move for judgment on the pleadings based on the three-year statute of limitations in the Wrongful Death Act, arguing that the claim was time-barred.

Alice Brice (Decedent) died in an automobile accident on September 13, 2006, when her 2002 Toyota Camry suddenly accelerated into a highway intersection, collided with a tractor-trailer, and burst into flames. The Estate of Alice C. Brice (Plaintiff) filed a wrongful death lawsuit on August 31, 2010, asserting products liability and various other claims against the car manufacturer, the dealer, and others (Defendants).

Issue

Whether the doctrine of fraudulent concealment may serve to toll the statutory limitations period for a cause of action under the Wrongful Death Act.

Whether the doctrine of fraudulent concealment may serve to toll the statutory limitations period for a cause of action under the WDA presents an issue of statutory interpretation, which we review de novo.

Rule

The doctrine of fraudulent concealment may apply to toll the statutory limitations period for a wrongful death claim if a defendant has fraudulently concealed a cause of action, thereby preventing the defendant from claiming the statute of limitations as a defense until the plaintiff learned or, through reasonable diligence, could have learned of the cause of action.

We hold that the doctrine of fraudulent concealment may apply to toll the statutory limitations period for a wrongful death claim if a defendant has fraudulently concealed a cause of action, thereby preventing that defendant from claiming the statute of limitations as a defense until the plaintiff learned or, through reasonable diligence, could have learned of the cause of action.

Analysis

The court analyzed the common law doctrine of fraudulent concealment and its applicability to the Wrongful Death Act. It determined that the doctrine serves to prevent defendants from benefiting from their own fraudulent conduct that conceals a cause of action from the plaintiff. The court found that the plaintiff had sufficiently alleged that the defendants concealed information regarding the sudden acceleration issue, which prevented the plaintiff from discovering the cause of action within the statutory period. Therefore, the court concluded that the statute of limitations should be tolled.

To resolve this issue of first impression, we discuss the common-law doctrine of fraudulent concealment and then examine whether the Legislature intended fraudulent concealment to apply to the limitations period in the WDA.

Conclusion

The Supreme Court reversed the district court's judgment and remanded the case, holding that the doctrine of fraudulent concealment applies to wrongful death actions under the Wrongful Death Act.

Accordingly we reverse and remand to the district court.

Who won?

The Estate of Alice C. Brice prevailed in the case because the Supreme Court recognized that the doctrine of fraudulent concealment could toll the statute of limitations, allowing the estate's claim to proceed despite being filed after the typical limitations period.

The Estate of Alice C. Brice prevailed in the case because the Supreme Court recognized that the doctrine of fraudulent concealment could toll the statute of limitations, allowing the estate's claim to proceed despite being filed after the typical limitations period.

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