Narrative Opinion Summary
In this case, the appellant, Wyatt, challenged a summary judgment that favored the respondent, Spartan Mill, on the grounds that her wrongful death lawsuit was barred by the statute of limitations. The case involved Wyatt’s father, who drowned in 1964, prior to her birth. Wyatt was appointed administratrix of his estate in February 1984, at the age of eighteen, and subsequently filed a wrongful death action. Under South Carolina law, specifically S.C. Code Ann. § 15-51-20, such actions can only be maintained by the estate's administratrix or executor, with a statute of limitations set at six years from the date of death per S.C. Code Ann. § 15-3-530(6). Wyatt argued that the statute of limitations was tolled during her minority, as per S.C. Code Ann. § 15-3-40, and she filed the suit timely upon reaching adulthood. However, the court found that since Wyatt was not an administratrix or executrix at the time of her birth, the tolling provision did not apply. Consequently, the court affirmed that her wrongful death action was barred by the statute of limitations, upholding the summary judgment in favor of Spartan Mill.
Legal Issues Addressed
Eligibility to Maintain Wrongful Death Actionssubscribe to see similar legal issues
Application: The court applied the principle that only the estate’s administratrix or executor may maintain wrongful death actions, and since Wyatt was not in such a position at her birth, she could not benefit from tolling.
Reasoning: According to S.C. Code Ann. § 15-51-20, only the estate’s administratrix or executor may maintain such actions... Wyatt was a potential beneficiary but not the administratrix or executrix.
Statute of Limitations in Wrongful Death Actionssubscribe to see similar legal issues
Application: The court held that the wrongful death action was barred by the statute of limitations, which is six years from the date of death.
Reasoning: The court affirms the judgment. Wyatt's father drowned in 1964, before her birth... and the statute of limitations is six years from the date of death per S.C. Code Ann. § 15-3-530(6).
Tolling of Statute of Limitations Due to Minoritysubscribe to see similar legal issues
Application: The court determined that the statute of limitations was not tolled during Wyatt's minority because she was not an administratrix or executrix at the time of her birth.
Reasoning: Wyatt contends that her minority tolled the statute... However, the court finds that at the time of her birth, Wyatt was a potential beneficiary but not the administratrix or executrix, thus not entitled to bring an action as defined in § 15-3-40.