Estes v. Tibbs

In Estes v. Tibbs, 1999 UT 52, 979 P.2d 823, Estes was imprisoned during the limitations period and lacked access to a lawyer and a law library. He claimed that his status was so exceptional and debilitating to asserting his claims in a timely way that the court should equitably toll the limitations period on his claims for the duration of his imprisonment. The Court disagreed, pointing out that he was able to file three pro se petitions from prison and could not reasonably explain why he would be unable to likewise file the actions foreclosed by the statute of limitations. In Estes v. Tibbs, the discovery rule was not at issue, but this court relied upon the language of prior discovery rule cases in holding that the statute of limitations would not be tolled for a plaintiff who had been imprisoned, lacking access to a lawyer or legal library. The court stated that it would not be "truly 'irrational' or 'unjust' to apply a statute of limitations" in that case. Id. Reserving equitable tolling for "more egregious circumstances," the court noted that "courts should be cautious in tolling a statute of limitations; liberal tolling could potentially cause greater hardships than it would ultimately relieve." Id.