R.R. v. New Life Community Church of CMA, Inc.
Resolving a certified conflict, the Florida Supreme Court held that courts may not create a judge-made delayed accrual rule for minors' tort claims; accrual is governed exclusively by section 95.031(1) (last element of the cause of action), with minority addressed only by the Legislature's tolling provision in section 95.051(1)(i). The Court approved the Fifth District's decision (and the Second District's reasoning in Adept) and disapproved the Third District's Drake and the Fourth District's Nur-Ul-Islam. The Court also refused to extend Hearndon v. Graham's delayed discovery rule beyond intentional tort claims against the perpetrator accompanied by traumatic amnesia, so plaintiffs' negligence and respondeat superior claims against the church and the abuser's parents were time-barred.
Key facts
- A minor plaintiff brought tort claims against a church and the abuser's parents for negligence and respondeat superior related to childhood sexual abuse.
- The trial court dismissed the claims as time-barred under Florida's statute of limitations, and the case reached the Florida Supreme Court on a certified conflict among the district courts regarding when a minor's tort claim accrues.
- +2 more key facts with a free trial
Why it matters
This decision eliminates a long-standing district split and forecloses the argument—previously available under Drake and Nur-Ul-Islam—that a minor's tort claim does not accrue until a parent knows or the minor turns 18… — full analysis with a trial
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