Parents, as personal representatives of estate of son who died while in Idaho Department of Juvenile Corrections (IDJC) custody, brought action against IDJC, IDJC employees, and physician assistant alleging wrongful death, negligence, and § 1983 claims.
The Sixth Judicial District Court granted summary judgment to physician assistant, granted summary judgment to IDJC and employees, and awarded IDJC and employees costs and attorney fees. Parents appealed.
The Supreme Court held that:
- Idaho Tort Claims Act’s (ITCA) notice requirement does not create a “statutory prohibition” to filing an action that tolls the limitations period until a response is received; abrogating Madsen v. Dept. of Health and Welfare, 116 Idaho 758, 779 P.2d 433;
- Limitations periods for state-law claims against employees and physician assistant were tolled pursuant to federal supplemental jurisdiction statute;
- As matter of first impression, 30-day tolling period under federal supplemental jurisdiction statute begins to run after the dismissal of the state law claim, regardless of the continuation or dismissal of other claims in federal action;
- Limitations periods for state-law claims against IDJC were tolled pursuant to federal supplemental jurisdiction statute;
IDJC was entitled to immunity under ITCA from claims; - Trial court did not abuse its discretion by granting attorney fees under § 1988 to IDJC and employees; and
- IDJC, employees, and physician assistant were prevailing parties on appeal.