In Saint Francis Memorial Hospital v. California Department of Public Health, the Supreme Court allows for the possibility of equitably tolling a 30-day statute of limitations for court challenges to administrative agency decisions. And it concludes that a challenger’s error in determining the statutory deadline “isn’t necessarily fatal” to an equitable tolling claim.
The court’s unanimous opinion by Justice Mariano-Florentino Cuéllar — an administrative law scholar (e.g., here) — holds that the Legislature’s specification of the 30-day period “doesn’t prohibit courts’ exercise of their equitable powers to toll that limitations period when justice so requires.”
But the court stresses that court tolling of legislatively adopted time periods “is a narrow remedy that applies . . . only ‘occasionally and in special situations.’ ” And in fact the court declines to decide whether tolling is appropriate for the petitioner in this case, a hospital challenging a $50,000 fine imposed by the State Department of Public Health for the hospital’s failure to develop and implement a surgical sponge count policy.
The court finds two elements of equitable tolling — timely notice and lack of prejudice to the Department — are satisfied. But the court vacates the decision of the First District, Division One, Court of Appeal, and it directs the appellate court to determine a third element — whether the hospital’s conduct was “reasonable and [in] good faith,” which, the court says, means conduct that is “objectively reasonable and subjectively in good faith.”
