Uchtorff v. Dahlin

LARSON, Justice

(dissenting).

I dissent from the majority’s refusal to apply the discovery rule for the reasons set out in division II of my dissent in Montgomery v. Polk County, 278 N.W.2d 911, 918-27, and for those following.

To require any claimant to sue on a claim of which he is unaware is unrealistic in any case, even those involving traditional, longer, statutes of limitations. Some flexibility, through a “discovery” rule or an equivalent is necessary, and we recognized that in Chrischilles v. Griswold, 260 Iowa 453, 150 N.W.2d 94 (1967). In a case with a much shorter limitation, such as the six-month provision of chapter 613A, the need for flexibility in a statute of limitations becomes even more imperative. Yet, while this court has recognized the discovery rule in the former class of cases, as it did in Chrischilles, it has denied it in the latter. See Montgomery, 278 N.W.2d at 914-18. See also Farnum v. G.D. Searle & Co., 339 N.W.2d 392, 396 (Iowa 1983).

The reason given for refusing to recognize the discovery rule is that, in contrast to “traditional” statutes of limitations, chapter 613A cases are creatures of statute. The time limitations contained in the statute are substantive, and compliance with them is a condition precedent to maintaining an action, according to this theory. Montgomery, 278 N.W.2d at 914-15.

The problem with this reasoning is that our tort claims act, which is remedial, is to be liberally construed. It gives no hint that it could not, or should not, accommodate application of the discovery rule. See Montgomery, 278 N.W.2d at 918 (McCormick, J. dissenting).

The federal tort claims act, 28 U.S.C. § 2401(b), also contains its own time limitation, providing that

[a] tort claim against the United States shall be forever barred unless it is presented in writing to the appropriate Federal agency within two years after such claim accrues or unless action is begun within six months after the date of mailing, by certified or registered mail, of notice of final denial of the claim by the agency to which it was presented.

Despite that fact, federal cases have applied the discovery rule to actions under that act. See, e.g., Casias v. United States, 532 F.2d 1339 (10th Cir.1976); Reilly v. United States, 513 F.2d 147 (8th Cir.1975); Jordan v. United States, 503 F.2d 620 (6th Cir.1974); Ciccarone v. United States, 486 F.2d 253 (3rd Cir.1973); Quinton v. United States, 304 F.2d 234 (5th Cir.1962).

The United States Supreme Court, moreover, has observed that

[t]he distinction between substantive and procedural statutes of limitations appears to have arisen in cases involving conflicts of laws, [Authorities cited.]. While the embodiment of a limitation provision in the statute creating the right which it modifies might conceivably indicate a legislative intent that the right and limitation be applied together when the right is sued upon in a foreign forum, the fact that the right and limitation are written into the same statute does not indicate a legislative intent as to whether or when the statute of limitations should be tolled. Thus the “substantive” — “procedural” distinction would seem to be of little help in deciding questions of extending the limitation period.

*269Burnett v. New York Central Railroad Co., 380 U.S. 424, 427, 85 S.Ct. 1050, 1054, 13 L.Ed.2d 941, 944, n. 2 (1965).

In enacting chapter 613A, allowing suits against municipalities, our legislature took a large step toward fairness; a person unaware of his claim should not be denied recourse simply because he was injured by a municipality. The notion that “the king can do no wrong,” it must have reasoned, is patently unfair. As I noted in my earlier dissent, however, the king can still do wrong with impunity — provided the injured party is unaware of it for six months or more. This result is not mandated by.our tort claims act; it is in fact repugnant to its remedial purposes.

HARRIS and McCORMICK, JJ., join this dissent.