History
  • No items yet
midpage
Jacobs v. Secretary Pennsylvania Department of Corrections
514 F. App'x 158
3rd Cir.
2013
Read the full case

Background

  • Jacobs, a Pennsylvania prisoner, sued prison officials in the Western District of Pennsylvania for 2003–2004 confinement in the LTSU and alleged mistreatment and denial of care.
  • He later alleged Drs. Kolli and Saavedra condoned confinement, under-diagnosed his condition, and experimented with antipsychotics.
  • The district court granted summary judgment, ruling claims were time-barred under Pennsylvania’s two-year SOL and limitations tolling.
  • Jacobs argued discovery in August 2005—upon reviewing his medical records—tolled the statute for his claims against Kolli and Saavedra.
  • The appellate panel reviews a grant of summary judgment de novo and affirms, applying discovery and tolling rules to the pleadings.
  • The court also found insufficient evidence of any experimentation to survive summary judgment.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the SOL and discovery rule toll the claims. Jacobs argues August 2005 discovery tolled. District court held claims time-barred. Claims time-barred; discovery tolling not established.
Whether discovery of mental illness tolled Kolli/Saavedra claims. August 2005 discovery reveals concealment; tolling applies. No concealment or newly discovered facts to justify tolling. No tolling; claims time-barred.
Whether Jacobs showed experimentation by doctors. Records show treatment as experimentation. No evidence of experimentation. Insufficient evidence of experimentation; not dispositive.
Whether concealment/fraud tolling applied. Defendants concealed facts about illness. No fraud proven. Tolling not established.
Whether summary judgment was proper given the record. Record creates genuine issue as to delayed discovery. Record shows time-barred and no triable facts. Summary judgment affirmed; claims time-barred.

Key Cases Cited

  • Lake v. Arnold, 232 F.3d 360 (3d Cir. 2000) (discovery rule tolls limitations for later discovery of injury)
  • Bohus v. Beloff, 950 F.2d 919 (3d Cir. 1991) (fraud-concealment tolling recognized)
  • Knopick v. Connelly, 639 F.3d 600 (3d Cir. 2011) (plenary review of summary judgment)
Read the full case

Case Details

Case Name: Jacobs v. Secretary Pennsylvania Department of Corrections
Court Name: Court of Appeals for the Third Circuit
Date Published: Feb 19, 2013
Citation: 514 F. App'x 158
Docket Number: 10-3792
Court Abbreviation: 3rd Cir.