Whether federal courts must apply equitable tolling principles when state notice statutes create procedural barriers for litigants with documented disabilities seeking judicial review

No question identified. : courts across jurisdictions have repeatedly confronted how equitable rights, statutory conflicts, and disability-related barriers operate in this context that often justify relief from strict compliance. 3. This case cleanly presents that issue with direct conflicts between the Tenth Circuit, state supreme court precedent, and decisions of this Court addressing equitable doctrines and meaningful access. Applicant, who had significant documented visual and cognitive impairments, relied on multiple state-agency representations that a hospital was a private institution outside any governmental oversight. Only after litigation commenced did Applicant discover that these assurances were false. Applicant then filed notice upon learning the hospital’s true governmental “character”. The lower courts, however, simply ignored the equitable doctrines and ignored requests to present evidence of disability-based barriers, and the evidence of related government misconduct which this Court and numerous state and federal courts recognize as considerations essential to meaningful access. The resulting conflict implicates fundamental due-process and access-to-justice principles recognized by this Court. 4. Under the legal framework at issue, Applicant filed suit for established federal EMTALA violations and related claims. The timely action was pursued based on the information available at the time, and the notice-of-claim issue arose only because multiple government state agencies repeatedly misrepresented the hospital’s governmental status, and both withheld and misstated investigative information related to the hospital's actions, as well as information regarding its regulatory oversight. The district court nevertheless dismissed the action while itself relying on the wrong version of the Governmental Claims Act—citing 2024 statutory amendments rather than the version controlling when the case was filed in 2023. It also did so without addressing state-supreme-court precedent and equitable principles governing notice despite their direct applicability, and without considering this Court’s established equitable-tolling jurisprudence under Holland v. Florida, 560 U.S. 631 (2010).S. 631 (2010). These errors illustrate a broader concern: when lower courts disregard controlling statutory text and equity principles in applying state notice statutes, the resulting consequences and barriers to judicial review raise federal dueprocess and access-to-justice concerns. 5. The Tenth Circuit’s unpublished decision compounded these errors and created direct conflicts with decisions of this Court and multiple courts of appeals. It affirmed dismissal without acknowledging the district court’s reliance on the wrong statutory text, misquoted Wyoming’s controlling governing notice framework, and categorically rejected equitable doctrines that this Court has recognized as preserved absent clear statutory displacement. See Holland. Its conclusion that Wyoming law provides no equitable relief, of any kind, for notice, contradicts the Wyoming Supreme Court’s holdings in Romero v. Brown, 899 P.2d 1342 (Wyo. 1995), and Hall v. Lincoln Mem’! Hosp., 991 P.2d 563 (Wyo. 1999)), and others, and places the Tenth Circuit in conflict with both state high courts and federal equitable-tolling precedent. Because the decision is unpublished, these conflicts remain unexamined and insulated from scrutiny while still shaping outcomes for litigants subject to rigid notice statutes throughout the Circuit and beyond. 6. The Tenth Circuit’s treatment of Applicant’s disability presents a separate and equally serious conflict with this Court’s precedent. Applicant’s documented visual and cognitive impairments directly affected his ability to gather information, decipher legal requirements, and meet procedural obligations. Yet both the district court and the court of appeals refused to consider disability-related barriers, ignored requests to submit medical evid