Rink v. Richland Memorial Hospital

Toal, Justice:

I respectfully dissent. The legislative goal in providing a longer, three-year statute of limitations for those who have first filed a claim with the governmental entity was clearly to encourage claimants to attempt informal resolution of their claim. As a less costly procedure, it benefits both the claimant and the governmental entity but it provides an additional benefit to the governmental entity in that the entity receives early notification of pending claims. The verified claim must be filed with the entity within one year of the loss occurred or when it should have been discovered. S.C. Code Ann. § 15-78-80(d) (Supp. 1991).

In Braudie v. Richland County, 219 S.C. 130, 64 S.E. (2d) 248 (1951), the applicable statute required, as a prerequisite to bringing a lawsuit, a verified claim to be filed within 180 days of the injury. The claimant did not file a verified claim but through her attorney appeared before the appropriate commission and wrote a letter to the county commission setting forth the details of her injury within two months of her injury. In Braudie, we noted the governmental entity had more information before it within forty-five days of the injury than was required to be furnished in one hundred and eighty days. Thus, we held the governmental entity had not only not been prejudiced but had benefitted from the claimant’s conduct. Therefore, the claimant should not be held to strict literal compliance of the statute.

*199As with the defendant in Braudie, in the case at bar, the Hospital received the benefit of the early claim. The claim was made within seven months of the injury. Although, this claim was not verified and the written notification did not provide all the alleged facts, it is clear from the record that a detailed investigation was conducted by the Insurance Reserve Fund’s adjuster. Furthermore, the plaintiff filed a lawsuit within a few months after the claim was denied by the insurance carrier. There was never a lapse in time when the Hospital was not on notice that this claim was being actively pursued. The Hospital then allowed Rink to invest substantial funds in extensive discovery for almost one year. Then the Hospital sought summary judgment on their statute of limitations defense. Rink’s actions clearly benefitted the Hospital more than a verified complaint filed one year after the injury would have and significantly more than the filing of a lawsuit within two years of the injury. Nevertheless, because of a technical nonconformity, the majority has denied Rink the return benefit provided by the legislature. I would hold Rink’s conduct, although not in strict conformity to the statute, benefitted the Hospital as much or more than a verified complaint would have, thus Rink should be entitled to the benefit of the extended statute of limitations.

Cochran v. City of Sumter, 242 S.C. 382, 131 S.E. (2d) 153 (1963), relied on by the majority, is distinguishable from the case at bar in that the applicable statute did not provide for alternate statutes of limitations but required a verified complaint to be filed with the agency within three months of the injury. There was no benefit conferred on the defendant by the plaintiffs noncompliance.

Additionally, I note the inequitable conduct of the defendant Hospital in delaying resolution of this issue by not filing a motion to dismiss on the statute of limitation defense until almost one year after this claim was filed.

Finney, J., concurs.