Watkins v. U.S.

Dist. Ct. did not err in dismissing on statute of limitations grounds plaintiff’s medical malpractice claim filed under Federal Tort Claims Act. Under FTCA, plaintiff was required to file instant lawsuit within 2 years of claim’s accrual, i.e., within 2 years of when plaintiff had enough information to suspect that her injuries had “doctor-related cause.” Moreover, Dist. Ct. could properly peg accrual date in instant 2015 action by taking judicial notice of plaintiff’s August 2010 state-court medical malpractice action arising out of same incident at issue in instant claim, since 2010 action was evidence of plaintiff’s awareness that instant defendant caused her injuries. Also, record showed that plaintiff did not present instant claim to relevant administrative agency until 4.5 years after claim’s accrual date. Fact that plaintiff alleged that she had suffered from mental illness since 2008 did not require different result.