John Doe 76C v. Archdiocese of St. Paul & Minneapolis

John Doe 76C (Doe) claimed the Archdiocese of St. Paul and Minneapolis and the Diocese of Winona (Dioceses) were liable for his damages resulting from alleged sexual abuse in the early 1980s by a priest under the Dioceses' control. Doe's claims were subject to six-year statutes of limitations. To support his argument that accrual of his claims was delayed and that his action was timely, Doe intended to offer general expert testimony on the theory of repressed and recovered memory. The district court concluded that Doe's expert testimony was inadmissible under the Frye-Mack standard, making his claims untimely, and granted the Dioceses summary judgment. The court of appeals reversed, concluding that Doe's expert testimony might be admissible under Minn. R. Evid. 702. The Supreme Court reversed, holding that Doe's expert testimony on the theory of repressed and recovered memory, offered to prove a disability delaying the accrual of a cause of action, was inadmissible under Rule 702 because it lacked foundational reliability and, as a result, Doe's claims were untimely. View "John Doe 76C v. Archdiocese of St. Paul & Minneapolis" on Justia Law