Falkenrath v. Candela Corporation, 374 P.3d 1028

In February 2009 Falkenrath suffered severe burns during a laser hair‑removal treatment performed by Elase, Inc. using a Candela‑manufactured machine. She knew she was injured at the time.
In January 2011 Falkenrath sued Elase for negligence; discovery in May 2012 produced Candela’s treatment guidelines.
In November 2012 she learned Elase employees received in‑person training from Candela.
Falkenrath did not move to amend her complaint to add Candela until December 2013 (4 years, 10 months after the injury). She says an expert report explaining Candela’s negligence arrived in October 2013, prompting the amendment.
Candela moved for summary judgment arguing the four‑year statute of limitations barred the claim; the district court granted summary judgment, ruling the statute began to run on the injury date and that equitable tolling (exceptional circumstances) did not apply.
On appeal the Utah Court of Appeals affirmed, holding Falkenrath failed to show exceptional circumstances justifying tolling and that the facts put her on notice to investigate Candela before the limitations period expired.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the four‑year statute of limitations was tolled as to Candela	Falkenrath: limitations should be tolled because she did not discover Candela’s role until her expert’s report in Oct 2013	Candela: limitations ran from the injury date and plaintiff had notice to investigate earlier	Held: No tolling; limitations ran from Feb 18, 2009 and claim is time‑barred
Whether equitable discovery/concealment exception applies	Falkenrath: unaware of Candela’s involvement until late; equitable tolling required	Candela: no concealment or misleading conduct; plaintiff had information to inquire	Held: No concealment; plaintiff failed to show exceptional circumstances
Whether mere ignorance of legal claim delays accrual	Falkenrath: argued claim ripened only when expert explained Candela’s negligence	Candela: accrual not delayed by plaintiff’s lack of legal knowledge	Held: Court rejects accrual based on later expert discovery; mere ignorance does not delay the statute
Whether summary judgment was appropriate	Falkenrath: disputed application of limitations and tolling	Candela: entitled to summary judgment as claim untimely	Held: Summary judgment affirmed—limitations bar applies

State v. Gallegos, 171 P.3d 426 (Utah 2007) (appellate review affords no deference to district court legal conclusions)
Berneau v. Martino, 223 P.3d 1128 (Utah 2009) (describes narrow scope of equitable tolling/exceptional circumstances)
Williams v. Howard, 970 P.2d 1282 (Utah 1998) (mere ignorance of cause of action does not prevent running of statute)
Hom v. Utah Dep’t of Public Safety, 962 P.2d 95 (Utah Ct. App. 1998) (plaintiff must exercise diligence once on notice of facts giving rise to claim)
Aragon v. Clover Club Foods Co., 857 P.2d 250 (Utah Ct. App. 1993) (personal injury from machinery commonly raises possible liability of both operator and manufacturer)
Brown v. State, 361 P.3d 124 (Utah Ct. App. 2015) (limitations period begins when plaintiff knows or could discover key facts, not when legal significance is recognized)