Guardian of involuntarily committed patient brought action on behalf of patient against state hospital and hospital administration officials alleging negligence and violation of her constitutional rights after patient was left unattended for an extended period of time.
The District Court found the negligence action time-barred and dismissed it, and also found that hospital officials were entitled to immunity. Patient appealed.
The Supreme Court of Wyoming held that:
- Causes of action accrued on the date of occurrence;
- Medical malpractice statute of limitations was not extended;
- State hospital, Department of Health, and hospital administrator in his official capacity were immune under Eleventh Amendment;
- Patient had a clearly established constitutional right, as required to sustain § 1983 action; and
- Patient alleged sufficient facts to state due process claim under § 1983.