C. William Helm v. Allison Ratterman

Summary

The Sixth Circuit affirmed the dismissal of Dr. Helm's 42 U.S.C. § 1983 due process claims as time-barred under Kentucky's one-year statute of limitations, holding that he knew or should have known of his injury by November 2015. The court reversed the dismissal of his fraud-by-omission claim, ruling that the district court erred in requiring inducement to act rather than recognizing that inducement to refrain from acting satisfies the element under Kentucky law. The case was remanded for the district court to determine whether a duty to disclose existed under alternative theories, and the remaining state-law claims were reinstated.

Holdings

1. The § 1983 claims are time-barred because Helm knew or should have known of his claim by November 19, 2015, more than a year before filing suit.
2. The district court erred in dismissing the fraud-by-omission claim because the inducement element can be satisfied by a showing that the plaintiff was induced to refrain from acting, not only to act.
3. Because the fraud-by-omission claim may be viable, the remaining state-law claims should be reconsidered on remand.

Questions Presented

1. Whether the district court correctly dismissed the § 1983 claims as time-barred.
2. Whether the district court correctly dismissed the fraud-by-omission claim for failure to plead inducement to act.
3. Whether the district court should have considered the remaining state-law claims.

Disposition

reversed_and_remanded