In re Estate of Manchester

May Manchester died in January 2004. Manchester had received Medicaid benefits through the Rhode Island Department of Human Services (DHS) (defendant). After Manchester’s death, DHS wrote a letter to Manchester’s daughter, Jean Curria (plaintiff), requesting to be notified when Manchester’s estate was submitted to probate. In June 2004, Manchester’s probate estate (plaintiff) opened, and the probate court published Curria’s appointment as the estate’s personal representative. However, DHS did not receive notice that Manchester’s probate estate was open until June 2007. In August 2007, DHS filed an estate recovery claim against Manchester’s estate to recover medical costs. The estate challenged, arguing that DHS’s claim was time-barred because (1) DHS failed to file its claim within three years of Manchester’s death, which was the applicable statute of limitations for claims arising prior to Manchester’s death; and (2) DHS failed to file a creditor lawsuit against the estate within two years of the probate court’s publication of Curria’s appointment as the estate’s personal representative. DHS countered and moved for summary judgment, arguing that the statute of limitations had not started to run until DHS received actual notice in June 2007 that Manchester’s probate estate was open. The trial court granted DHS’s motion for summary judgment, holding that DHS’s recovery claim against Manchester’s estate was not time-barred. The estate appealed.