Mellett v. Fairview Health Services

Summary

The Minnesota Supreme Court held that the plaintiff's false imprisonment claim against Dr. Johnson was barred by the two-year statute of limitations. Service of process on the Fairview defendants did not constitute service on Dr. Johnson, despite the alleged joint enterprise between them. The court reversed the court of appeals and reinstated summary judgment for Dr. Johnson.

Holdings

1. Service of process on one participant in an alleged joint enterprise does not constitute service on another participant for statute-of-limitations purposes absent a civil-procedure rule authorizing such service.
2. Mellett's false imprisonment claim accrued on January 21, 1997, when the alleged actual confinement ended, not on January 24, 1997, when the commitment petition was dismissed.

Questions Presented

1. Whether the court of appeals properly inferred the existence of a joint enterprise between Dr. Johnson and the Fairview defendants.
2. Whether service of process on one participant in an alleged joint enterprise constitutes service on all participants for statute-of-limitations purposes.
3. Whether Mellett's false imprisonment claim accrued on January 24, 1997, rather than January 21, 1997, because the commitment petition was dismissed on January 24.

Disposition

reversed