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Sloan v. Canadian Valley Animal Clinic, Inc.
Citations: 719 P.2d 474; 1985 OK CIV APP 39; 1985 Okla. Civ. App. LEXIS 87Docket: 62661
Court: Court of Civil Appeals of Oklahoma; November 19, 1985; Oklahoma; State Appellate Court
Sandra K. Sloan, the Appellant, worked as a volunteer at the Canadian Valley Animal Clinic, where she contracted Brucellosis, a disease linked to cattle. After experiencing illness, she was diagnosed with Brucellosis in August 1981, following several hospital visits for related symptoms. The Appellees, including various veterinarians, filed a motion for summary judgment, claiming her personal injury action was barred by the two-year Statute of Limitations since she first felt unwell in April 1981. However, the Appellant contended that her claim should be governed by the "discovery rule," which states that the statute of limitations begins when a plaintiff discovers or should have discovered the injury and its cause. The court sided with the Appellant, noting that Brucellosis is rare, with fewer than 200 cases diagnosed annually in the U.S., and she was not aware of her condition until months after her initial contact with infected cattle. The court acknowledged the general rule that ignorance of a cause of action does not extend the statute of limitations but also recognized exceptions in specific contexts, such as medical malpractice and environmental damage cases. Ultimately, the court found that the Appellant's cause of action had not accrued until her diagnosis in August 1981, allowing her claim to proceed. In Williams v. Borden, the plaintiff developed "meat wrapper's syndrome," a chronic pulmonary condition, after inhaling toxic fumes from a plastic film used in meat packaging. Initially misdiagnosed, the plaintiff's situation prompted a legal examination of the statute of limitations regarding her claim. The Federal Court reversed the trial court's summary judgment for the defendant, establishing that the statute of limitations for such claims only commences once the plaintiff is aware, or should reasonably be aware, of both the condition and the defendant's role in causing it. Although the federal ruling is not binding, the reasoning was deemed persuasive for the current court. The court concluded that due to the uncertainty surrounding the plaintiff's diagnosis and the delay in understanding the cause of her illness, the statute of limitations had not begun to run. Consequently, the trial court erred in granting summary judgment, as there remained factual questions about the plaintiff's awareness of her condition and its cause. The summary judgment was reversed, and the case was remanded for further proceedings. Judges Reynolds and Gray concurred.