Chiaramonte v. Santa Cruz Big Trees & Pacific Railway Co.
Docket: No. 07-17234
Court: Court of Appeals for the Ninth Circuit; May 12, 2009; Federal Appellate Court
Equitable tolling may be applied when a plaintiff, despite exercising due diligence, cannot obtain essential information regarding their claim. In Santa Maria v. Pacific Bell, the court clarified that Chiaramonte presented no evidence of ignorance about his injury or of any efforts to investigate a potential claim under the Federal Employers’ Liability Act (FELA). Consequently, he is not entitled to equitable tolling due to his complete lack of inquiry regarding his options, as established in Huseman v. Icicle Seafoods, Inc. Chiaramonte also contended that his employer, Santa Cruz Big Trees Pacific Railway Co. (SCBT), should be equitably estopped from invoking the statute of limitations since SCBT assisted him in obtaining California workers’ compensation without informing him of his FELA claim. The equitable estoppel analysis emphasizes the defendant's actions that may have hindered the plaintiff from filing suit, requiring the plaintiff to show both actual and reasonable reliance on the defendant's conduct. The court found it unreasonable for Chiaramonte to believe that SCBT’s help with workers’ compensation indicated that no federal remedies were available. Therefore, the court affirmed the decision, noting that this disposition is not for publication and does not serve as precedent except as outlined by 9th Cir. R. 36-3.