Legal Memorandum: Equitable Estoppel and Statute of Limitations

Issue: Under Iowa law, may a defendant in a tort or medical malpractice action be equitably estopped from asserting a statute of limitations defense when fraudulent concealment is involved?

Under Iowa Supreme Court precedent in Christy v. Miulli, 692 N.W.2d 694, 703 (Iowa 2005) TA l "Christy v. Miulli, 692 N.W.2d 694 (Iowa 2005)" s "Christy v. Miulli  (Iowa 2005)" c 1 , a defendant may be equitably estopped from raising the statute of limitations defense.  In Christy, the court explained that “the doctrine of fraudulent concealment … estops a defendant raising a statute-of-limitations defense … when it would be inequitable to permit the defendant to do so.”  Id. at 701 TA s "Christy v. Miulli  (Iowa 2005)" .  Christy held:

The foundational elements of equitable estoppel are well established:

(1) The defendant has made a false representation or has concealed material facts; (2) the plaintiff lacks knowledge of the true facts; (3) the defendant intended the plaintiff to act upon such representations; and (4) the plaintiff did in fact rely upon such representations to his prejudice.

Id. at 702 (quoting Meier v. Alfa-Laval, Inc., 454 N.W.2d 576, 578-79 (Iowa 1990)). 

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