Kathleen Betts v. Wendell Hall
679 F. App'x 810
| 11th Cir. | 2017Background
- Pro se plaintiff Kathleen Betts sued under 42 U.S.C. §§ 1983, 1985, 1986 and Florida law, ultimately naming Santa Rosa County law‑enforcement officers, a state attorney, and jail physician Dr. Epstein.
- Betts filed five amended complaints; initial suit was filed January 2014 and included events dating back to 2006–2009.
- The district court dismissed with prejudice several federal claims arising from pre‑January 2010 discrete incidents as time‑barred under Florida’s four‑year residual personal‑injury limitations period.
- The court also dismissed with prejudice Betts’s Eighth/medical deliberate‑indifference and equal‑protection claims against Dr. Epstein for failure to state a claim.
- Remaining state‑law claims were dismissed without prejudice; plaintiff appealed, arguing (1) limitations rulings should be saved by equitable tolling/continuing‑violation doctrines, (2) Dr. Epstein claims were sufficient, and (3) the court abused its discretion in declining supplemental jurisdiction.
- The Eleventh Circuit affirmed: limitations dismissal was proper, deliberate‑indifference and equal‑protection claims against the physician were inadequately pleaded, and declining supplemental jurisdiction was not an abuse of discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pre‑Jan 2010 §1983 claims are time‑barred | Betts: continuing violation or equitable tolling extend limitations | Defendants: claims are discrete events that accrued when they occurred; no extraordinary circumstances | Court: Claims time‑barred; continuing‑violation inapplicable; equitable tolling not shown |
| Whether deliberate indifference to serious medical needs was pleaded against Dr. Epstein | Betts: Dr. Epstein gave platelet‑destroying med and provided inadequate treatment | Defendants: allegations, at best, show disagreement/ negligence, not subjective deliberate indifference | Court: Dismissed for failure to state Eighth Amendment deliberate‑indifference claim |
| Whether equal‑protection claim against Dr. Epstein pleaded | Betts: alleges discrimination (no factual support in brief) | Defendants: no factual allegations supporting discriminatory intent | Court: Dismissed for lack of any factual support |
| Whether district court abused discretion by declining supplemental jurisdiction over state claims | Betts: federal dismissal shouldn't force state forum; she can’t get meaningful relief in state court | Defendants: with federal claims dismissed, comity, economy and Gibbs factors favor dismissal | Court: No abuse of discretion; dismissal without prejudice was appropriate |
Key Cases Cited
- Berman v. Blount Parrish & Co., 525 F.3d 1057 (11th Cir. 2008) (standards for de novo review of statute‑of‑limitations application)
- Starship Enters. of Atlanta, Inc. v. Coweta Cnty., 708 F.3d 1243 (11th Cir. 2013) (standards for de novo review of Rule‑12(b)(6) dismissals)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard; reject bare legal conclusions)
- Mullinax v. McElhenney, 817 F.2d 711 (11th Cir. 1987) (accrual rule for §1983 claims)
- Wallace v. Kato, 549 U.S. 384 (2007) (accrual principles in section‑based claims)
- Hipp v. Liberty Nat’l Life Ins. Co., 252 F.3d 1208 (11th Cir. 2001) (continuing‑violation doctrine explanation)
- Lovett v. Ray, 327 F.3d 1181 (11th Cir. 2003) (distinction between present consequence of one‑time violation vs. continuing violation)
- Arce v. Garcia, 434 F.3d 1254 (11th Cir. 2006) (equitable tolling requires extraordinary circumstances and diligence)
- Estelle v. Gamble, 429 U.S. 97 (1976) (deliberate indifference standard for prisoner medical claims)
- McElligott v. Foley, 182 F.3d 1246 (11th Cir. 1999) (medical malpractice vs. constitutional deliberate indifference)
- Baggett v. First Nat. Bank of Gainesville, 117 F.3d 1342 (11th Cir. 1997) (Gibbs factors and comity in supplemental‑jurisdiction decision)
- Palmer v. Hosp. Auth. of Randolph Cty., 22 F.3d 1559 (11th Cir. 1994) (considerations for declining supplemental jurisdiction)
- Mergens v. Dreyfoos, 166 F.3d 1114 (11th Cir. 1999) (encouragement to dismiss state claims when federal claims are dismissed pretrial)
- United Mine Workers v. Gibbs, 383 U.S. 715 (1966) (framework for federal‑state claim adjudication and supplemental jurisdiction)