Muraoka v. Budget Rent-a-Car, Inc.

John Muraoka (plaintiff) was injured on July 31, 1980, in a collision with another car that was owned by Budget Rent-a-Car (Budget) (defendant). Muraoka notified Budget of the accident, and on September 4, 1980, Budget requested more information. In response, Muraoka sent Budget copies of his medical bills. On October 21, 1980, Budget acknowledged receipt of Muraoka’s medical bills and asked Muraoka to sign and return a medical-information release form before it could settle. On April 23, 1981, Budget requested information about Muraoka’s medical treatment from his doctor. On June 15, Muraoka’s agent informed Budget that Muraoka had not heard from Budget and was concerned because it had been almost a year since the accident. The agent also relayed that Muraoka wanted to settle the claim without litigation. On August 14, Budget told Muraoka that his medical reports had not yet been received. When Muraoka called his doctor to inquire about that, he was told that they had never been requested. On that same day, Budget requested the reports from Muraoka’s doctor, and they were sent out on September 23. On October 22, Budget offered to settle Muraoka’s claim. On October 26, Muraoka turned down the offer. Budget told Muraoka that its offer was final. On November 3, Muraoka told Budget that he wanted an equitable settlement or that he would file a lawsuit. On November 9, Budget informed Muraoka that it had completed its review and was denying Muraoka’s claim and closing its file because the applicable one-year limitations period had passed since the date of the accident. On June 30, 1982, Muraoka filed a lawsuit against Budget. The trial court sustained Budget’s demurrers that the claims were barred by the one-year statute of limitations. Muraoka appealed.