Cullen v. District of Columbia

The administrator of an estate appeals from a summary judgment entered in favor of the District of Columbia upon its complaint seeking to recover the costs of care and maintenance for decedent while she was a patient at St. Elizabeths Hospital.1 Appellant contends that the statute of limitations 2 precludes any recovery against the estate because the action was not filed until more than nine years after the last payment was made on the account in 1955.

The decedent, Rachel Berry, was a patient at the institution from July 30, 1940, to May 17, 1941, and again from January 29,1951, until…