Florida Department of Health and Rehabilitative Services v. S.A.P.

S.A.P. (defendant) was a foster child under the supervision and care of the Florida Department of Health and Rehabilitative Services (HRS) (plaintiff), a state agency. In 1979, law enforcement discovered that S.A.P., then only four years old, had been abused and severely neglected by her foster parents. After the abuse was discovered, HRS actively interfered with the police investigation, altered records, and falsified reports to conceal HRS’s negligent supervision of S.A.P. HRS’s internal investigation of S.A.P.’s abuse was not completed until 1992. S.A.P. filed a negligence claim against HRS in 1995 after attaining the age of majority. HRS moved to dismiss S.A.P.’s claim, arguing that it was time-barred by the applicable four-year statute of limitations. S.A.P. countered, arguing that the doctrine of equitable estoppel barred HRS from raising a statute-of-limitations defense because HRS’s fraudulent concealment of material facts involving S.A.P.’s abuse and HRS’s negligent supervision prevented S.A.P. from filing her negligence claim within the four-year statute of limitations. The trial court dismissed S.A.P.’s claim as untimely. S.A.P. appealed. The appellate court reversed, holding that S.A.P.’s claim was timely because HRS’s fraudulent concealment tolled the statute of limitations. HRS appealed to the Florida Supreme Court, arguing that the doctrine of equitable estoppel was inapplicable to tort claims filed against state agencies.