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Fila v. Spruce Mountain Inn (178 Vt. 323, 885 A.2d 723)

Vermont-elderly-man-nursing-home-neglect-abuse-300x200Articles: Vermont

Fila v. Spruce Mountain Inn (178 Vt. 323, 885 A.2d 723)

CASE:
Fila v. Spruce Mountain Inn (178 Vt. 323, 885 A.2d 723)
PARTIES:
Plaintiff (Appellee) – Virginia Fila
Defendant (Appellant) – Spruce Mountain Inn and Candace Beardsley
COURT:
Supreme Court of Vermont (2005)
PROCEDURAL HISTORY:

Virginia Fila, a patient at the Defendant residential psychiatric facility, sued Spruce Mountain Inn and the facility’s director, Candace Beardsley, alleging negligent supervision stemming from an incident where Fila was allegedly sexually assaulted by a male staff member of the facility. Defendant’s moved for summary judgment. The trial court granted the motion. Fila appealed.

SUMMARY OF FACTS:

Virginia Fila entered the Spruce Mountain Inn (“SMI”), a residential facility for individuals with psychiatric problems, in December 1995 at the age of 23. She had a long history of mental illness and had been hospitalized for them nine times before.

While at SMI, Fila was continually troubled by flashbacks, anxiety, and depression, and had at least one dissociative episode. Fila alleges that in late 1995, while a resident at SMI, she took an overdose of a prescribed sedative, and later awoke to find a male patient in her bed having sex with her.

Fila continued a brief sexual relationship with the other patient, but she contends that the episode in question was non- consensual and that she did not remember the incidents clearly, suggesting that she was in a dissociative state most of the time. The  male patient was asked by SMI staff to leave the facility, but Fila believed for many years that she was at fault for the alleged sexual assaults.  In February 1996, Fila discovered that she was pregnant.  Fila moved out of the facility and in with her mother in September 1996.

Over the next several years, Fila was periodically hospitalized on almost 50 separate occasions on average of about a month. In October 2000, Fila moved with her mother and sister to New York. She began therapy and through those sessions came to understand that she had been sexually assaulted while at SMI. In March 2001, she filed the action for negligent supervision among other claims.

Defendants moved for summary judgment, asserting that the claim was barred by the three- year statute of limitations. Although Fila agreed that the cause of action had accrued in January 1996, and that the statute of limitations normally would have expired in January 1999, she argued that the statute had been tolled from the date of accrual to the end of October 2000, when she came to understand what had happened to her.

OUTCOME AT TRIAL:

The trial court granted the Defendant’s motion for summary judgment.

ISSUES ON APPEAL:

Did the trial court err in granting summary judgment and denying plaintiff the chance to have the question of her competence or sanity resolved by the jury for purposes of determining whether statute of limitations was tolled due to her insanity?

SUPREME COURT HOLDINGS:
Yes
RELEVANT APPLICATION OF LAW:
The definition of “insanity” under § 551 is whether a person’s “mental disability makes him unable to manage his business affairs or estate, or to comprehend his legal rights and liabilities.”

  • Goode v. State, 147 Vt. 646, 514 A.2d 322 (1986)

The Supreme Court ruled that the trial court applied an erroneous legal standard in determining that plaintiff was not “insane” for purposes of tolling the statute of limitations under § 551.

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