Sandra Vasquez-Garcia, a former prisoner at the Western New Mexico Correctional Facility, filed a complaint under 42 U.S.C. § 1983 alleging that prison officials and private healthcare contractors were deliberately indifferent to her serious medical needs, violating her Eighth and Fourteenth Amendment rights. Vasquez-Garcia suffered from diabetes and other conditions, and she alleged that medical staff failed to provide proper medication, diet, and monitoring, leading to worsening kidney disease, vision loss, and heart failure. After she was released in May 2021, she filed suit in the District of New Mexico in May 2024. The defendants moved to dismiss, arguing that her claims were time-barred by New Mexico's three-year statute of limitations. The district court granted the motion, inferring that Vasquez-Garcia knew of her injury and the defendants' conduct well before the three-year window closed, and dismissed all claims with prejudice, including those against defendants who had not been properly served.
The Tenth Circuit, in an opinion by Circuit Judge Federico, held that the district court erred by resolving the statute of limitations defense at the pleading stage. The court explained that while the statute of limitations for § 1983 claims in New Mexico is three years, the accrual date is a question of federal law determined by when the plaintiff knew or should have known of the injury and the facts giving rise to the legal claim. For deliberate indifference claims, this requires knowledge of two elements: the objective seriousness of the injury and the defendant's subjective state of mind. The court reasoned that a plaintiff does not need to know that the law has been violated, but must know the facts that tie the injury to the defendant's deliberate indifference. The court found that Vasquez-Garcia's complaint plausibly alleged that she could not have known the defendants' subjective state of mind until after her release, when her health deteriorated to a point where the connection between the lack of care and her condition became clear. The district court improperly engaged in fact-finding by assuming Vasquez-Garcia knew of the defendants' indifference earlier than the complaint supported. Additionally, the court addressed the continuing violations doctrine, noting that while it generally requires unlawful acts within the limitations period, it applies here because the failure to treat a chronic condition can be viewed as a continuous violation that persisted until her release. Finally, the court noted a jurisdictional error in the district court's dismissal of claims against defendants who were never served.
The case is remanded to the district court for further proceedings. The dismissal is reversed, allowing Vasquez-Garcia to proceed with her claims. On remand, the district court must conduct an evidentiary analysis to determine the specific timing of when Vasquez-Garcia discovered the defendants' deliberate indifference and whether the continuing violations doctrine applies based on the evidence developed. The court must also address the jurisdictional issue regarding the defendants who were never served, as the district court lacked personal jurisdiction over them and could not dismiss claims against them with prejudice.
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