Fraudulent concealment

Fraudulent concealment is a common law doctrine that may be invoked to toll a statute of limitations. Under it, if a defendant has concealed his misconduct, the limitations period starts from the point when the plaintiff discovers the claim, or should have discovered it with due diligence. It is similar to the equitable estoppel doctrine. The United States Supreme Court first adopted the doctrine as a matter of federal common law in the 1874 case Bailey v. Glover, and it was later raised in cases connected with the Watergate scandal, where E. Howard Hunt invoked it unsuccessfully and Hedrick Smith used it successfully.