SANDRA VASQUEZ-GARCIA v. CENTURION, LLC; CENTURION CORRECTIONAL HEALTHCARE OF NEW MEXICO, LLC; MHM HEALTH PROFESSIONALS, INC.; WEXFORD HEALTH SOURCES INC.; SUMMIT FOOD SERVICE L...
The Tenth Circuit reversed a district court's dismissal of a prisoner's Eighth Amendment medical care claims, holding that the lower court erred by applying a pleading standard to a statute of limitations defense that requires factual development. The court clarified that accrual of a deliberate indifference claim depends on when a plaintiff knew or should have known of the defendant's subjective state of mind, a determination inappropriate for resolution on a Rule 12(b)(6) motion.