## Facts

- Anita Knaysi had a Dalkon Shield intrauterine device (IUD) manufactured by A.H. Robins inserted by her gynecologist.
- She became pregnant while using the IUD and, during the first trimester, suffered a spontaneous septic abortion of twin fetuses.
- The Knaysis alleged that Robins had test results and physician reports indicating the device was less effective than advertised and was associated with spontaneous septic abortions.
- The Knaysis alleged Robins concealed adverse information and continued to issue false advertising to physicians and the public about the device’s safety and efficacy.
- The Knaysis sued Robins and its insurer on theories including negligence, breach of warranty, strict liability, fraud, conspiracy, and outrageous conduct.
- The action was filed after the applicable limitations period under New York law, and the Knaysis asserted that Robins’ conduct should estop Robins from invoking the statute of limitations.

## Issues

1. Under New York law, whether the plaintiffs’ fraud allegations supported equitable estoppel preventing the defendant from asserting a statute-of-limitations defense.
2. Whether genuine disputes of material fact existed regarding the plaintiffs’ reliance and diligence, making summary judgment improper.

## Decision

- The Eleventh Circuit reversed the district court’s grant of summary judgment and remanded.
- The court held the complaint alleged sufficiently specific concealment and misrepresentations that, if proven, could establish equitable estoppel under New York law.
- The court concluded that material fact disputes existed as to whether the defendant’s conduct prevented timely suit and whether the plaintiffs acted within a reasonable time after discovery (or when they should have discovered) the basis for the claim.

## Legal Principles

- Under New York law, equitable estoppel can bar a statute-of-limitations defense when a defendant’s affirmative misconduct (including misrepresentations or concealment) caused the plaintiff to delay filing suit.
- A plaintiff must show defendant conduct that actually induced delay and that the plaintiff filed within a reasonable time after learning of the relevant facts or when those facts should have been learned through reasonable diligence.
- Reliance, causation of delay, and reasonable diligence commonly present fact questions not suitable for resolution on summary judgment where the record permits competing inferences.

## Conclusion

The Eleventh Circuit held that allegations of specific concealment and misleading promotional statements about a medical device could, if proven, estop a limitations defense under New York law, and that disputes about reliance and diligence required further proceedings rather than summary judgment.


Knaysi v. A.H. Robins Co., 679 F.2d 1366 (11th Cir. 1982)