Teeters v. Currey

Brief Fact Summary.

Plaintiff underwent a procedure to prevent her from having more children. The procedure was unsuccessful and she delivered a premature child as a result. She brought suit against the defendant, the physician who performed the operation. Defendant alleged that the suit was barred by Tennessee’s statute of limitations.

Synopsis of Rule of Law.

In a medical malpractice suit, a cause of action begins to accrue and the statute of limitations begins to run when the patient discovers or reasonably should have discovered the resulting injury.

Facts.

Teeters (plaintiff) gave birth to a child and Currey (defendant) was the attending physician. Teeters suffered medical complications as a result of the delivery. Currey recommended that Teeters undergo a tubal ligation, a sterilization procedure that would prevent future pregnancies. Teeters agreed and underwent the surgery. Two and a half years later, she became pregnant again. Teeters delivered a premature child nearly three years after the unsuccessful tubal ligation. Teeters suffered severe complications as a result of the delivery. She underwent a second tubal ligation. Teeters sued Currey for negligently and inadequately performing the first tubal ligation. She brought suit three years, five months and nine days after Currey had performed the procedure, but approximately eleven months after discovering her second pregnancy. The trial court held that Teeters’ suit was barred by the state’s statute of limitations. Teeters appealed.

Issue.

Whether the statute of limitations begins to run from the date of the injury or from the date of discovery of the injury?

Held.

The statute of limitations begins to run from the date of discovery of the injury. Here, the statute of limitations began when Teeters discovered that she was pregnant again. Her suit against Currey is not barred by the statute of limitations. The case is reversed and remanded.

Discussion.

Tennessee law had previously followed the principle that ignorance or failure to discover the existence of a cause of action does not prevent the statute of limitations from running. However, the court acknowledges that this view is harsh and oppressive. The court now adopts the discovery doctrine, which states that the statute of limitations begins to run once the negligent is, or should have been, discovered. Here, the statute began to run once Teeters discovered she was pregnant again. The trial judge had relied on the court’s precedents in ruling that Teeter’s claim was barred by the statute. However, the discovery doctrine is now the proper doctrine to apply in the matter at hand. The case is therefore reversed and remanded.