Johnny Timpson v. Anderson County Disabilities, No. 20-1163 (4th Cir. 2022)
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The plaintiffs filed suit in South Carolina state court against fourteen defendants (ten individuals and four agencies), alleging five causes of action. The circuit court reviewed five preserved issues: (1) the applicable statutes of limitations for plaintiffs' claims under the Rehabilitation Act ("RA") and the Americans with Disabilities Act ("ADA"); (2) whether the district court abused its discretion in limiting a certain testimony; (3) whether the district court improperly instructed the jury as to the South Carolina Tort Claims Act ("SCTCA"); (4) whether the district court improperly dismissed plaintiff’s RA claims; and (5) whether the court erred in dismissing plaintiff’s 1983 claims.
First, the Fourth Circuit held that the district court erred in applying a one-year statute of limitations, finding the three-year statute of limitations for general civil actions applied. Next, the court affirmed the district court’s decision to limit the testimony of one of the plaintiffs based on potential confusion to the jurors due to competency issues. Further, the Fourth Circuit found that the district court did not abuse its discretion by limiting the hybrid witness's testimony or by denying the plaintiffs' request to depose one of the defendants.
The Fourth Circuit also held that the district court did not abuse its discretion when it instructed the jury that, under the SCTCA, the defendants could only be held liable if they acted with gross negligence. Finally, the district court did not err in dismissing the plaintiffs' RA and ADA claims.
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