Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

plaintiffdefendantliabilitystatutemotioncorporationproduct liabilitystatute of limitationsmotion to dismiss
plaintiffdefendantstatutemotionstatute of limitationsmotion to dismiss

Related Cases

Shu-Tao Lin v. McDonnell Douglas Corp., 742 F.2d 45, 39 Fed.R.Serv.2d 958, 16 Fed. R. Evid. Serv. 487
View Case »
McIntosh v. Melroe Co., a Div. of Clark Equipment Co., Inc., 729 N.E.2d 972, Prod.Liab.Rep. (CCH) P 15,814
View Case »
Cain v. Johnson, 755 A.2d 156, 146 Ed. Law Rep. 259
View Case »
Westby v. Itasca County, 290 N.W.2d 437
View Case »
Hanover v. Ruch, 809 S.W.2d 893
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

Renaud v. Sigma-Aldrich Corp., 662 A.2d 711, Prod.Liab.Rep. (CCH) P 14,324

Facts

On February 3, 1988, Sharon R. Renaud was injured after inhaling fumes from acetic acid that had spilled at Landmark Medical Center. She experienced symptoms shortly after the exposure and sought medical treatment. Renaud initially filed a product liability action against Sigma-Aldrich Corporation in 1991, later discovering that Fisher Scientific Company was the actual supplier of the container. After learning this, she amended her complaint to include Fisher as a defendant in 1993, but Fisher moved to dismiss the case based on the statute of limitations.

On February 3, 1988, plaintiff, Sharon R. Renaud, was injured as a result of inhaling fumes from acetic acid that had spilled at her place of employment, Landmark Medical Center (Landmark).

Issue

Did the statute of limitations bar the plaintiff's claim against Fisher Scientific Company after it was added as a defendant?

Did the statute of limitations bar the plaintiff's claim against Fisher Scientific Company after it was added as a defendant?

Rule

The statute of limitations for personal injury actions in Rhode Island is three years from the date the cause of action accrues, which is typically at the time of injury.

The three-year statute was a reasonable legislative enactment that fully comported with the constitutional entitlement to remedies for wrongs and injuries.

Analysis

The court determined that Renaud's cause of action accrued on the date of her injury, February 3, 1988. The court found that the statute of limitations had expired by the time Renaud amended her complaint to include Fisher in 1993. The court also ruled that any alleged misrepresentation by her employer or others did not toll the statute of limitations, as there was no evidence that Fisher had concealed the existence of the cause of action.

Even if we accept each of plaintiff's allegations as true, they provide no basis for tolling the statute of limitations on a cause of action against Fisher.

Conclusion

The Supreme Court granted Fisher's petition for certiorari, quashed the order of the Superior Court denying Fisher's motion to dismiss, and remanded the case with directions to grant the motion to dismiss.

The petition for certiorari is granted, and the order denying Fisher's motion to dismiss is quashed.

Who won?

Fisher Scientific Company prevailed in the case because the court found that the statute of limitations had expired before Renaud could properly include it as a defendant.

Fisher's motion to dismiss was therefore denied. Fisher thereafter filed this petition for certiorari, seeking review of the denial of its motion to dismiss.

You must be