Inman v. Boykin
2014 WY 94
Wyo.2014Background
- Inman alleges Boykin negligently operated a vehicle, causing a collision on July 9, 2008 in Evanston, Wyoming.
- Inman filed a complaint on June 28, 2012 against Boykin and Midwest Car Corp. d/b/a National Car Rental.
- Inman sought a 120-day enlargement to effect service; the court granted October 26, 2012 extension.
- Boykin was served November 5, 2012 with a defective summons; a corrected summons was served December 12, 2012.
- The four-year statute of limitations expired July 8, 2012; service occurred after expiration with relation-back issues.
- District court granted dismissal with prejudice on June 11, 2013, and Inman appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the motion to dismiss became a summary judgment | Inman argues extraneous evidence converted the motion. | Boykin contends no valid conversion occurred due to improper notice. | Conversion ineffective; treated as party’s dismissal order, reviewed as such. |
| Whether equitable estoppel prevents a statute of limitations defense | Insurer’s promises to settle delayed service, creating estoppel. | Insurer’s conduct did not induce delay; no misrepresentation or promise to forego limitations. | Equitable estoppel not established; estoppel does not bar the statute. |
| Whether Archuleta controls the estoppel analysis in this case | Archuleta-like reasoning supports estoppel here. | Archuleta is distinguishable; no estoppel. | Archuleta supports no estoppel; court rejects estoppel here. |
Key Cases Cited
- Archuleta v. City of Rawlins, 942 P.2d 404 (Wyo. 1997) (insurer delay without mislead does not establish estoppel)
- Hoke v. Motel 6 Jackson, 131 P.3d 369 (Wyo. 2006) (Rule 6(b)(2) cannot extend the statute of limitations)
- Ridgerunner, LLC v. Meisinger, 297 P.3d 110 (Wyo. 2013) (conversion of Rule 12 motion to summary judgment requires notice and opportunity to respond)
- Cranston v. Weston County Weed and Pest Bd., 826 P.2d 251 (Wyo. 1992) (notice and response requirements for conversion of motion)
- Newport Int’l Univ. v. Wyo. Dep’t of Educ., 186 P.3d 382 (Wyo. 2008) (summary judgment standard and burden-shifting framework)
- Johnson v. Griffin, 922 P.2d 860 (Wyo. 1996) (statute of limitations analysis in Wyoming)