Doe v. Roman Catholic Bishops of Sacramento

Jane Doe (plaintiff) worked for the Roman Catholic Bishop of Sacramento (the diocese) (defendant) for over 20 years. Jose Urbina and Gerardo Beltran were priests within the diocese, acted as Doe’s spiritual advisors, and were frequently left alone with Doe’s children. In the late 1980s, Beltran and Urbina molested two of Doe’s children; however, the children did not report the molestation until 2008. In 1989, Urbina pleaded guilty to unrelated child-molestation charges and fled the county. In 1991, Beltran was accused of child molestation and fled the county. The diocese did not tell Doe, or any other parishioners, that the accusations against Urbina and Beltran were credible. In 2008, Doe sued the diocese for fraud and negligence, alleging that the diocese’s failure to disclose Urbina’s and Beltran’s pedophilia allowed Urbina and Beltran to be in the position to molest Doe’s sons. The diocese demurred, arguing that Doe’s claims were time-barred by the applicable statutes of limitations. The trial court sustained the demurrer and dismissed Doe’s complaint, holding that (1) Doe’s claims were time-barred; and (2) the applicable statutes of limitations were triggered approximately 20 years prior when Doe learned that both Beltran and Urbina had been accused of child molestation. Doe appealed, arguing that the statutes of limitations were tolled until her sons reported the molestations in 2008.