Sally Boland, Sherri Lynn Harper, David C. Gann, Jennirae Littrell, Natural Daughter of Decedent Clarence Bailey Warner, Helen Pittman, Natural Sister of Decedent Shirley R. Eller v. Saint Luke's Health System, Inc., and Saint Luke's Hospital of Chillicothe f/k/a The Grand River Health System Corporation d/b/a Hedrick Medical Center, and Community Health Group, 471 S.W.3d 703

Five wrongful death actions against a hospital were consolidated in Missouri Supreme Court.
Decedents died in 2002 while treated at Hedrick Medical Center; allegations involve physician Hall's suspected killings and hospital concealment.
Plaintiffs argue fraudulent concealment prevented accrual or tolled the three-year limit under section 537.100.
Trial courts granted judgments on the pleadings, holding claims time-barred by section 537.100.
Frazee v. Partney remains controlling; wrongful death accrues at death with no tolling for concealment under 537.100.
Court emphasizes legislative intent and that equity cannot rewrite the statute of limitations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Frazee governs accrual and tolling for wrongful death.	Frazee should not bar claims due to concealment.	Frazee controls; accrual at death with no tolling for concealment.	Frazee remains good law; accrual at death; no fraud tolling.
Whether fraudulent concealment tolls or delays accrual under section 537.100.	Beisly/estoppel should toll or delay accrual.	Section 537.100 has no tolling for concealment; fraudulent concealment not an exception.	No tolling or delayed accrual under 537.100; no statutory exception.
Whether equitable estoppel can prevent reliance on statute of limitations.	Hospital’s concealment bars assertion of limitations defense.	No equitable estoppel due to lack of affirmative acts causing delay.	Equitable estoppel not recognized to override 537.100 as pleaded.
Whether legislative history supports an exception to 537.100 for fraudulent concealment.	Legislative inaction implies a tolling exception should exist.	Legislature could have, but did not, enact a fraud tolling; Frazee remains controlling.	Legislative intent supports no fraud tolling; Frazee controls.

Frazee v. Partney, 314 S.W.2d 915 (Mo. banc 1958) (special statute of limitations must carry its own exceptions; no tolling for fraud)
O’Grady v. Brown, 654 S.W.2d 904 (Mo. banc 1983) (wrongful death act promotes legislative objectives; consider purposes with statute)
Howell v. Murphy, 844 S.W.2d 42 (Mo. App. 1992) (concludesFrazee superseded; fraudulent concealment tolling discussed)
Laughlin v. Forgrave, 432 S.W.2d 308 (Mo. banc 1968) (discovery rule not extended to general cases; legislature governs tolling rules)
Weiss v. Rojanasathit, 975 S.W.2d 113 (Mo. banc 1998) (discovery doctrine limited; equitable estoppel analysis discussed)
Perry v. Strawbridge, 108 S.W.641 (Mo. 1908) (common law maxims against fraud; legislative reception statute applied)
Glus v. Brooklyn Eastern Dist. Terminal, 359 U.S.231 (Supreme Court 1959) (equitable estoppel applies to prevent asserting advantage from fraud)
Cummins v. Kansas City Pub. Serv. Co., 66 S.W.2d 920 (Mo. banc 1933) (remedial wrongful-death purpose grounded in common law history)