Peter Meyer v. Gwinnett County
716 F. App’x 857
| 11th Cir. | 2017Background
- Meyer was jailed for ~20 months on child-sexual-abuse charges that were later dropped; he was released December 28, 2011. He alleges physical and sexual abuse in jail and severe mental/physical deterioration.
- Meyer filed suit in January 2014 asserting state claims (malicious prosecution, false imprisonment, defamation) and a § 1983 claim; most claims have a two‑year statute of limitations in Georgia.
- Meyer conceded his suit was untimely but invoked Georgia tolling statutes for legal incapacity (O.C.G.A. §§ 9‑3‑90, 9‑3‑91), alleging two discrete periods of incapacity: the first three weeks after release and a one‑month period in May–June 2013.
- The district court, after limited discovery on tolling, granted summary judgment for defendants: it held (1) Meyer had sufficient capacity during the three weeks after release to manage ordinary affairs, and (2) even if incapacitated in May–June 2013, that period did not significantly affect filing timing because Meyer had counsel earlier—Meyer did not challenge the second ground on appeal.
- On appeal the Eleventh Circuit reviewed de novo and held there is a genuine dispute of material fact about Meyer’s mental capacity during the three‑week period after release, relying on Meyer’s testimony, affidavit evidence from coworkers, and three affidavits from his treating therapist that he suffered CPTSD and was functioning on "auto‑pilot."
- Court vacated summary judgment as to tolling for the three‑week period and remanded for further proceedings; the defamation claim (1‑year limit) was affirmed as untimely and other procedural points (service dismissal, etc.) were not disturbed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Meyer was legally incapacitated for the three weeks after release so as to toll the limitations period | Meyer: trauma-induced CPTSD left him incapable of managing ordinary affairs (couldn’t initiate behavior, acted on "auto‑pilot", depended on others) | Defendants: Meyer’s actions (securing employment, walking to work, signing forms, basic hygiene, performing tasks) show sufficient capacity; diagnosis alone insufficient | There is a genuine issue of material fact as to incapacity during the three weeks; summary judgment vacated and remanded |
| Whether alleged incapacity in May–June 2013 tolls limitations because it did not significantly affect timing of the suit | Meyer asserted this period of incapacity | Defendants: Meyer had counsel by May 2012, so later incapacity didn’t materially delay filing; tolling would be unfair to defendants | Court affirmed district court—Meyer abandoned appeal on this point; held forfeited |
| Whether plaintiff’s own testimony and treating‑therapist affidavits can create a triable issue on incapacity | Meyer relied on his testimony and Dr. Aldridge’s affidavits that he lacked capacity | Defendants relied on Meyer’s deposition admissions and employer affidavits indicating functional activities | Court: testimony and affidavits create conflicting evidence for jury; denial of tolling at summary judgment improper |
| Standard for legal incapacity under Georgia law | Meyer: applied Georgia test—incapable of managing ordinary affairs due to mental illness (capacity test) | Defendants: emphasized that diagnoses without evidence of inability to manage affairs are insufficient under precedent | Court applied Georgia standards and found disputed facts preclude summary judgment; issue for jury |
Key Cases Cited
- Williams v. City of Atlanta, 794 F.2d 624 (11th Cir.) (federal § 1983 claims borrow state personal‑injury limitations period)
- Anderson v. Liberty Lobby, 477 U.S. 242 (summary judgment standard: court asks whether genuine dispute for trial exists)
- Bradley v. Franklin Collection Serv., Inc., 739 F.3d 606 (11th Cir.) (standard of review for summary judgment)
- Martin v. Herrington Mill, LP, 730 S.E.2d 164 (Ga. Ct. App.) (Georgia tolling statute confined to situations where it is unfair to charge the suitor because of mental condition; diagnosis alone insufficient)
- Tri‑Cities Hosp. Auth. v. Sheats, 273 S.E.2d 903 (Ga. Ct. App.) (incapacity is usually a jury question; test is inability to manage ordinary affairs)
- Chapman v. Burks, 357 S.E.2d 832 (Ga. Ct. App.) (clarifies capacity test: not whether affairs were managed poorly but whether plaintiff lacked capacity)
- Charter Peachford Behavioral Health Sys. v. Kohout, 504 S.E.2d 514 (Ga. Ct. App.) (plaintiff’s testimony may rebut incapacity; professional opinions must address incapacity to be sufficient)
- Carter v. Glenn, 533 S.E.2d 109 (Ga. Ct. App.) (diagnoses without an opinion that plaintiff could not manage ordinary affairs do not satisfy tolling standard)