Carol English v. James Taylor, D.O.

Summary

The Idaho Supreme Court affirmed summary judgment dismissing Carol and Eric English's medical negligence claims against James Taylor, D.O., and Eastern Idaho Health Services, Inc. The court held that, under Idaho law, an action adding new defendants commences when the amended complaint is filed, not when a motion for leave to amend is filed, and therefore the claims were barred by the medical malpractice statute of limitations. The court also awarded Eastern Idaho Health Services attorney fees on appeal.

Holdings

1. State law, rather than Federal Rule of Civil Procedure 3 or other federal procedural law, determines when the action commenced for purposes of tolling Idaho's medical-malpractice statute of limitations.
2. When an amended complaint adds new parties to an existing action, the action against those new parties commences when the amended complaint itself is filed, not when a motion for leave to amend is filed.
3. The claims against Dr. Taylor and Eastern Idaho Health Services were barred by Idaho's medical-malpractice statute of limitations because the second amended complaint adding them was filed after the limitations period expired.
4. Eastern Idaho Regional Medical Center was entitled to reasonable attorney fees on appeal because the appeal was frivolous, unreasonable, and without foundation.

Questions Presented

1. Whether Idaho or federal law determines when the Englishes' medical-malpractice claims commenced for purposes of tolling Idaho's statute of limitations.
2. Whether filing a motion for leave to amend, rather than filing the amended complaint itself, commenced claims against new parties under Idaho law.
3. Whether Eastern Idaho Regional Medical Center was entitled to attorney fees on appeal.

Disposition

affirmed