Jenkins v. United States of America

In Jenkins v. United States of America, federal inmate Michael Jenkins sued the government under the Federal Tort Claims Act (FTCA), alleging that negligent dental care at a federal prison led to severe infection and permanent injury. The district court dismissed the complaint as time-barred, finding he failed to file within the FTCA's two-year statute of limitations. On March 20, 2024, the U.S. Court of Appeals for the Fourth Circuit reversed, holding that the "continuous treatment doctrine" applied, which tolls the limitations period while a patient remains under a provider’s ongoing care. The appellate court determined Jenkins’ claim was timely because his dental problems were continuous and he had sought repeated treatment, making the dismissal premature. The case was remanded for further proceedings.

The Fourth Circuit reversed the district court’s dismissal and remanded the case for further proceedings, allowing the medical negligence claim to proceed.

Whether the district court properly dismissed the FTCA claim as time-barred, or whether the continuous treatment doctrine tolled the statute of limitations due to ongoing medical care.

The ruling reinforced inmate access to federal courts for medical malpractice claims and clarified the application of the continuous treatment doctrine under the FTCA, setting an important precedent for prisoner litigation and government liability.