Joseph Omar Sabir v. NaphCare Inc., Amanda Spayde, Michelle Johnson, Spokane County, Sgt. Robert Brittos, Officer Thomas, Officer Phillips, Officer Moser, Officer Rasmussen, Officer Howard, and Officer Epley

Summary

The United States District Court for the Eastern District of Washington partially granted and partially denied defendants’ motion to dismiss Joseph Omar Sabir’s Third Amended Complaint. The court held that the claims against NaphCare, Inc. and Amanda Spayde were not time-barred and sufficiently pleaded, but claims against Michelle Johnson were time-barred because they did not relate back. The court dismissed the common-law negligence and gross-negligence claims against NaphCare and Spayde, while allowing the medical-negligence and § 1983 claims to proceed against the remaining defendants.

Holdings

1. Sabir's § 1983 claims were timely because the applicable three-year Washington limitations period was extended by 145 days of tolling for his pretrial detention, and the initial complaint was filed before the resulting June 29, 2024 deadline.
2. The Third Amended Complaint related back to the original complaint as to NaphCare and Amanda Spayde because the claims arose from the same conduct, the defendants had notice, and the pleadings' earlier references resulted from mistakes concerning identity.
3. The claims against Michelle Johnson were time barred because she was first named after expiration of the limitations period and there was no evidence that she should have known she would have been named but for a mistake concerning identity.
4. The Third Amended Complaint sufficiently stated § 1983 claims against the challenged defendants by alleging a timeline of medical requests, denials, and other actions relevant to deliberate indifference to serious medical needs.
5. Washington Revised Code § 7.70 provides the exclusive remedy for injuries arising in the healthcare context, so Sabir's common-law negligence and gross-negligence claims against NaphCare and Spayde were dismissed.

Questions Presented

1. Whether Sabir's 42 U.S.C. § 1983 claims were barred by the applicable statute of limitations.
2. Whether the Third Amended Complaint related back to the original complaint as to NaphCare and Amanda Spayde under Federal Rule of Civil Procedure 15(c)(1).
3. Whether the claims against Michelle Johnson related back to the original complaint despite her addition after expiration of the limitations period.
4. Whether the Third Amended Complaint sufficiently pleaded Fourteenth Amendment deliberate-indifference claims under § 1983.
5. Whether Washington's medical-negligence statute provided the exclusive remedy for the alleged healthcare-related injuries and required dismissal of common-law negligence and gross-negligence claims.

Disposition

other