Curtin v. City of E. Wenatchee , Nos. 36209-4-III, 36210-8-III, 2020 Wash. App. LEXIS 264 (Ct. App. Feb. 6, 2020)
Issues: (1) Are pre-majority medical expenses (damages for medical expenses incurred prior to
one’s eighteenth birthday) only recoverable by a minor’s parents, since the parents are financially
responsible for the minor’s care and maintenance? NO. (2) Does the tolling provision in Wash.
Rev. Code § 4.16.190, which pauses the statute of limitations until a minor attains the age of
competency to bring claims on his or her own behalf, permit a parent or guardian to “bootstrap”
their own untimely claim to the minor’s claim? NO.