Skwira v. United States, 344 F.3d 64 (1st Cir. 2003). · Go Syfert
Skwira v. United States, 344 F.3d 64 (1st Cir. 2003). Cases Citing This Book View Copy Cite
“ailure to comply with the ftca's statute of limitations means that the district court lacks subject matter jurisdiction to entertain the suit and must dismiss it.”
409 citation events (409 in the last 25 years) across 27 distinct courts.
Strongest positive: LAUZON v. DODD (med, 2019-07-09)
Treatment trajectory · 2003 → 2026 · click a year to view as-of
2003 2014 2026
Top citers, strongest first. 50 distinct citers.
examined Cited as authority (verbatim quote) LAUZON v. DODD (3×) also: Cited as authority (rule)
D. Me. · 2019 · quote attribution · 1 verbatim quote · confidence high
nder the discovery rule, definitive proof of wrongful conduct and government liability is not required to start the period for filing a claim.
discussed Cited as authority (verbatim quote) Salls v. Digital Federal Credit Union
D. Mass. · 2018 · signal: see · quote attribution · 1 verbatim quote · confidence high
lower federal courts 'generally apply a discovery rule when a statute is silent on the issue.
examined Cited as authority (verbatim quote) Morales-Melecio v. United States (4×) also: Cited as authority (rule), Cited "see", Cited "see, e.g."
D.P.R. · 2016 · signal: see · quote attribution · 1 verbatim quote · confidence high
a cause of action for death is complete when death occurs.
discussed Cited as authority (verbatim quote) Yacubian v. United States (2×) also: Cited as authority (rule)
D. Mass. · 2013 · quote attribution · 1 verbatim quote · confidence high
one does not have to be certain of actionability in order to submit an administrative claim.
discussed Cited as authority (quoted) Salls v. Digital Fed. Credit Union
unknown court · 2018 · signal: see · quote attribution · 1 verbatim quote · confidence high
lower federal courts 'generally apply a discovery rule when a statute is silent on the issue.
discussed Cited as authority (quoted) Calderón-López v. United States (2×) also: Cited "see, e.g."
usdistct · 2018 · quote attribution · 1 verbatim quote · confidence low
ailure to comply with the ftca's statute of limitations means that the district court lacks subject matter jurisdiction to entertain the suit and must dismiss it.
discussed Cited as authority (rule) Urizar-Mota v. United States
1st Cir. · 2026 · confidence medium
"For a putative plaintiff to preserve his or her legal rights in the context of the FTCA, he or she must . . . file an administrative claim indicating: '(1) sufficient information for the agency to investigate the claims, and (2) the amount of damages sought.'" Ouellette v. Beaupre, 977 F.3d 127, 141 (1st Cir. 2020) (quoting Skwira v. United States, 344 F.3d 64, 70 (1st Cir. 2003) (emphasis added)); see 28 C.F.R. § 14.2 (a).
cited Cited as authority (rule) WILSON
D. Me. · 2025 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003). 2.
cited Cited as authority (rule) Soto v. of Puerto Rico
D.P.R. · 2025 · confidence medium
McCulloch v. Velez, 364 F.3d 1, 5 (1st Cir. 2004); Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003); Murphy v. United States, 45 F.3d 520, 522 (1st Cir. 1995).
cited Cited as authority (rule) Mango Labs, LLC v. Kramer
D.P.R. · 2025 · confidence medium
McCulloch v. Velez, 364 F.3d 1, 5 (1st Cir. 2004); Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003); Murphy v. U.S., 45 F.3d 520, 522 (1st Cir. 1995).
examined Cited as authority (rule) O'Brien v. United States (4×) also: Cited "see"
1st Cir. · 2025 · confidence medium
Skwira v. United States, 344 F.3d 64, 72 (1st Cir. 2003).
cited Cited as authority (rule) Kennedy v. Osmanski, III
D. Mass. · 2025 · confidence medium
Skwira v. United States, 344 F.3d 64, 72 (1st Cir. 2003) (citing United States v. Mitchell, 445 U.S. 535, 538 (1980)).
cited Cited as authority (rule) Smith v. United States
D. Mass. · 2025 · confidence medium
Skwira v. United States, 344 F.3d 64, 73 (1st Cir. 2003) (citing United States v. Kubrick, 444 U.S. 111, 113 (1979)).
discussed Cited as authority (rule) Lawrence v. Dejoy
D. Mass. · 2025 · confidence medium
“It is ‘elementary’ that the United States, as sovereign, is immune from suit unless it has consented to be sued.” Skwira v. United States, 344 F.3d 64, 72 (1st Cir. 2003) (quoting United States v. Mitchell, 445 U.S. 535, 538 (1980)); see also FAA v. Cooper, 566 U.S. 284, 290 (2012) (“[A] waiver of sovereign immunity must be ‘unequivocally expressed’ in statutory text.”).
discussed Cited as authority (rule) Lisi v. Federal Bureau of Prisons
E.D.N.Y · 2025 · confidence medium
“Once a duty to inquire is established, the plaintiff is charged with the knowledge of what he or she would have uncovered through a reasonably diligent investigation.” McIntyre, 367 F.3d at 52 (citing Skwira v. United States, 344 F.3d 64, 77 (1st Cir. 2003)).
cited Cited as authority (rule) SHUTE v. PROVINCE OF NEW BRUNSWICK
D. Me. · 2025 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003).
cited Cited as authority (rule) LaBonte v. Riverside Park Enterprises, Inc
D. Mass. · 2025 · confidence medium
Skwira v. United States, 344 F.3d 64, 71-72 (1st Cir. 2003).
cited Cited as authority (rule) William Spencer & Spencer Brothers LLC v. P U.S. Department of Transportation, et al.
D.N.H. · 2024 · confidence medium
Skwira v. United States, 344 F.3d 64, 72 (1st Cir. 2003).
cited Cited as authority (rule) Spencer v. US Department of Transportation
D.N.H. · 2024 · confidence medium
Skwira v. United States, 344 F.3d 64, 72 (1st Cir. 2003).
cited Cited as authority (rule) HOSPITAL AMERIMED CANCUN S A DE C V v. MARTINS POINT HEALTH CARE INC
D. Me. · 2024 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003).
cited Cited as authority (rule) HOSPITAL QUIRURGICA DEL SUR v. MARTINS POINT HEALTH CARE INC
D. Me. · 2024 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003).
discussed Cited as authority (rule) Doe v. UMass - Amherst
D. Mass. · 2023 · confidence medium
Importantly, “the knowledge which triggers accrual (and hence the running of the statute of limitations) is the discovery of sufficient facts about the injury and its cause to prompt a reasonable person to inquire and seek advice,” Skwira v. United States, 344 F.3d 64, 78 (1st Cir. 2003) (emphasis added), not the plaintiff’s knowledge or discovery of the law, as Plaintiff argues.
discussed Cited as authority (rule) Doe v. UMass - Amherst
D. Mass. · 2023 · confidence medium
Importantly, “the knowledge which triggers accrual (and hence the running of the statute of limitations) is the discovery of sufficient facts about the injury and its cause to prompt a reasonable person to inquire and seek advice,” Skwira v. United States, 344 F.3d 64, 78 (1st Cir. 2003) (emphasis added), not the plaintiff’s knowledge or discovery of the law, as Plaintiff argues.
discussed Cited as authority (rule) Krick v. Raytheon Company (2×)
D. Mass. · 2023 · confidence medium
Skwira v. United States, 344 F.3d 64, 74 (1st Cir. 2003).
cited Cited as authority (rule) VANETTEN v. DAIGLE
D. Me. · 2023 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003).
cited Cited as authority (rule) DESMARAIS v. HAMILTON
D. Me. · 2023 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003).
discussed Cited as authority (rule) Roldon-Barrios v. Department of Veterans Affairs (2×) also: Cited "see"
D.P.R. · 2023 · confidence medium
Importantly, “definitive knowledge of the cause of injury is not required to trigger the accrual of a medical malpractice claim . . .” Skwira v. United States, 344 F.3d 64, 78 (1st Cir. 2003).
cited Cited as authority (rule) Quiles-Quiles v. United States
D.P.R. · 2021 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003).
discussed Cited as authority (rule) Solimino v. Target Corporation
D. Mass. · 2021 · confidence medium
To the contrary, “[i]n a situation where the parties dispute the predicate facts allegedly giving rise to the court’s jurisdiction, the district court will often need to engage in some preliminary fact-finding.” Skwira v. United States, 344 F.3d 64, 71-72 (1st Cir. 2003).
cited Cited as authority (rule) ABDI v. TEPLER
D. Me. · 2021 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003).
cited Cited as authority (rule) BAILEY v. DEJOY
D. Me. · 2021 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003). 2.
examined Cited as authority (rule) Ouellette v. Beaupre (3×) also: Cited "see", Cited "see, e.g."
1st Cir. · 2020 · confidence medium
See id. at 11, 19 (extortion); Skwira, 344 F.3d at 67-68, 74-75 (wrongful - 17 - ignorance of the facts, including an injury and its cause, and ignorance of the law.
cited Cited as authority (rule) Jay Redford v. U.S. Department of Housing and Urban Development, et al.
D.N.H. · 2020 · confidence medium
Skwira v. United States, 344 F.3d 64, 72 (1st Cir. 2003).
cited Cited as authority (rule) Redford v. US Department of Housing and Urban Development
D.N.H. · 2020 · confidence medium
Skwira v. United States, 344 F.3d 64, 72 (1st Cir. 2003).
cited Cited as authority (rule) KNOX v. ALLSTATE PROPERTY AND CASUALTY INSURANCE COMPANY
D. Me. · 2020 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003).
cited Cited as authority (rule) GOGUEN v. United States
D. Me. · 2020 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003).
discussed Cited as authority (rule) Alvisuriz v. Bjorkman
D. Mass. · 2020 · confidence medium
“It is ‘elementary’ that the United States, as sovereign, is immune from suit unless it has consented to be sued.” Skwira v. United States, 344 F.3d 64, 72 (1st Cir. 2003) (quoting United States v. Mitchell, 445 U.S. 535, 538 (1980)).
cited Cited as authority (rule) Mello v. United States
D. Mass. · 2020 · confidence medium
Skwira v. United States, 344 F.3d 64, 73 (1st Cir. 2003).
examined Cited as authority (rule) FRECHETTE v. GAUDETTE (5×) also: Cited "see"
D. Me. · 2019 · confidence medium
Skwira v. United States, 344 F.3d 64, 77 (1st Cir. 2003).
examined Cited as authority (rule) OUELLETTE v. GAUDETTE (5×) also: Cited "see"
D. Me. · 2019 · confidence medium
Gonzalez, 284 F.3d at 289 . 2 The federal discovery rule allows courts to be “slightly more forgiving” in cases when “the identity of the individual(s) responsible for an injury [is] less evident” and the circumstances that gave rise to the injury did not give the plaintiff “reason to suspect governmental involvement.” Skwira v. United States, 344 F.3d 64, 77 (1st Cir. 2003).
discussed Cited as authority (rule) CARPENTER v. United States
D. Me. · 2019 · confidence medium
The plaintiff, as “the party invoking the jurisdiction of a federal court[,] carries the burden of proving its existence.” Skwira v. United States, 344 F.3d 64, 71 (1st Cir. 2003) (quoting Murphy v. United States, 45 F.3d 520, 522 (1st Cir. 1995)).
discussed Cited as authority (rule) Barrigas v. United States of America
D. Mass. · 2018 · confidence medium
Plaintiff, as “the party invoking the jurisdiction of a federal court[,] carries the burden of proving its existence.” Skwira v. United States, 344 F.3d 64, 71 (st Cir. 2003) (citation and quotation marks omitted).
cited Cited as authority (rule) Clean Water Action v. Searles Auto Recycling, Corp.
D. Mass. · 2017 · confidence medium
Skwira v. United States, 344 F.3d 64, 71-2 (1st Cir. 2003).
discussed Cited as authority (rule) Irish v. Irish
1st Cir. · 2016 · confidence medium
A district court’s “conclusion regarding the existence vel non of subject matter jurisdiction is a question of law subject to de novo review.” Skwira v. United States, 344 F.3d 64, 72 (1st Cir. 2003).
cited Cited as authority (rule) Trafon Group, Inc. v. Butterball, LLC
1st Cir. · 2016 · confidence medium
See Montalvo v. González-Amparo, 587 F.3d 43 , 46 (1st Cir.2009); Skwira v. United States, 344 F.3d 64, 72 (1st Cir.2003).
cited Cited as authority (rule) Alers v. Barceló
D.P.R. · 2016 · confidence medium
Skwira v. United States, 344 F.3d 64, 71 (1st Cir.2003).
discussed Cited as authority (rule) Lukas v. United States
D. Mass. · 2015 · confidence medium
“It is ‘elementary’ that the United States, as sovereign, is immune from suit unless it has consented to be sued.” Skwira v. United States, 344 F.3d 64, 72 (1st Cir.2003) (quoting United States v. Mitchell, 445 U.S. 535, 538 , 100 S.Ct. 1349 , 63 L.Ed.2d 607 (1980)).
discussed Cited as authority (rule) Sheldon Stephens v. Kevin Clash
3rd Cir. · 2015 · confidence medium
X v. Multi-Vision Elecs., Inc., 491 F.3d 938 , 944 (8th Cir.2007))); Skwira v. United States, 344 F.3d 64, 73-74 (1st Cir.2003) (holding discovery rule applicable to wrongful death claims under the Federal Tort Claims Act (FTCA) despite statutory language indicating that such claims “shall be forever barred” absent written notice “within two years after such claim accrues” (quoting 28 U.S.C. § 2401 (b))); cf. Plaza Speedway Inc. v. United States, 811 F.3d 1262 , 1267-68 (10th Cir.2002) (noting that “the general statute of limitations accrual rule in non-medical malpractice FTCA case…
discussed Cited as authority (rule) Pipitone v. City of New York
E.D.N.Y · 2014 · confidence medium
“Once a duty to inquire is established, the plaintiff is charged with the knowledge of what he or she would have uncovered through a reasonably diligent investigation.” McIntyre, 367 F.3d at 52 (citing Skwira v. United States, 344 F.3d 64, 77 (1st Cir.2003)).
discussed Cited as authority (rule) United States v. Steward
D. Mass. · 2014 · confidence medium
See also F.D.I.C. v. Meyer, 510 U.S. 471, 475 , 114 S.Ct. 996 , 127 L.Ed.2d 308 (1994) (“Absent a waiver, sovereign immunity shields the Federal Government and its agencies fromsuit.”); United States v. Mitchell, 445 U.S. 535, 538 , 100 S.Ct. 1349 , 63 L.Ed.2d 607 (1980) (noting that there is no jurisdiction “[i]n the absence of clear congressional consent”); Callahan v. United States, 426 F.3d 444, 450 (1st Cir.2005) (quoting Skwira v. United States, 344 F.3d 64, 72 (1st Cir.2003)) (“It is ‘elementary’ that the United States, as sovereign, is immune from suit unless it has conse…
Skwira
v.
United States
02-1988.
Court of Appeals for the First Circuit.
Sep 15, 2003.
344 F.3d 64

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