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Keywords

tortjurisdictiondamageslawyernegligencestatutesummary judgmentstatute of limitations

tortmotionsummary judgment

Related Cases

Holloway v. United States, 845 F.3d 487

Facts

Holloway was injured on June 22, 2012, while receiving treatment at Caring Health Center, a federally funded facility. He filed an administrative claim with the Department of Health and Human Services (HHS) on April 8, 2014, but did not specify a sum certain, which is a requirement for the claim to be considered presented. HHS acknowledged the claim and requested additional documentation, but Holloway's lawyer submitted the necessary documents only after the two-year statute of limitations had expired. HHS ultimately denied the claim, stating that the evidence did not establish that the injuries were due to the negligence of a federal employee.

Holloway is injured while receiving treatment at Caring Health Center, Inc., a federally funded healthcare facility in Springfield, Massachusetts.

Issue

Did Holloway timely present his claim under the Federal Tort Claims Act by providing a sum certain?

Rule

Under the FTCA, a claim must be presented to the relevant administrative agency within two years after it accrues, and it must include a demand for money damages in a sum certain. Failure to comply with this requirement can bar the claim.

A key FTCA requirement is that a person cannot sue under it unless he first presents his “claim” to the relevant administrative agency “within two years after such claim accrues”—failure to present a claim within that period “forever bar[s]” the claim.

Analysis

The court found that Holloway did not timely specify a sum certain in his claim, nor did he provide documents that would allow for the determination of such a sum within the required timeframe. The magistrate judge concluded that Holloway's submissions did not meet the necessary criteria, and the court agreed that there were no extraordinary circumstances that would warrant equitable tolling of the limitations period.

The magistrate judge treated the motion as one for summary judgment and recommended that judgment enter for the United States. Her reasoning ran this way. For starters, she concluded that Holloway had neither timely specified a sum certain nor timely provided documents from which “such a sum could be ascertained” and so had not properly presented his claim to HHS.

Conclusion

The court affirmed the summary judgment in favor of the United States, concluding that Holloway's failure to provide a timely sum certain deprived the court of jurisdiction over his claim.

For the reasons expressed above, we affirm the judgment entered below.

Who won?

The United States prevailed in the case because Holloway failed to meet the FTCA's requirements for presenting his claim, specifically the sum certain requirement.

The United States is quick to point out.

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