Court: Court of Appeals of Iowa; June 26, 2013; Iowa; State Appellate Court
Martha and Larry Lane filed a lawsuit against Spencer Municipal Hospital for injuries Martha sustained from a fall in a hospital bathroom on February 28, 2010. They submitted their petition on February 29, 2012. The hospital moved to dismiss the case, arguing the two-year statute of limitations had expired. The district court initially agreed but later determined the filing was timely, reasoning that by excluding February 28, 2010, and counting forward two years, the deadline fell on February 29, 2012.
Disagreement arose over the correct expiry date of the limitations period. Spencer Hospital asserted that the lawsuit was due by February 28, 2012, while the Lanes contended February 29, 2012, was valid since the first day of the period was excluded. The court clarified that, according to Iowa law, the last day to file the lawsuit was indeed February 28, 2012, making the February 29 filing one day late. The court emphasized that regardless of whether the period is counted in days or months, the completion of two years from the injury date resulted in February 28, 2012. The court dismissed the relevance of the leap year, stating that the statute of limitations had already expired before February 29, 2012, and confirmed that a year is treated the same regardless of the number of days it contains.
A leap year adds an extra day, which is considered as one day when measuring time in years. Definitions of "year" can vary, with some interpretations indicating a year as a fixed 12-month period starting from any designated month, not strictly from January 1 to December 31. However, in Yeinsip v. Lufthansa Ger. Airlines, it was ruled that for a one-year statute of limitations, a leap year should be counted as having 366 days. The court found that an action filed on February 1, 1989, was timely. The district court's decision to revisit and overturn its original dismissal of Spencer Municipal Hospital’s motion was deemed erroneous. Consequently, the court reversed the decision and remanded the case for reinstatement of the original dismissal order. Judge Vogel did not participate, Judge Mullins concurred, and Judge Taror dissented. Relevant statutes cited include Iowa Code §§ 4.1(40) and 4.1(16).
