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John Doe BF v. Diocese of Gallup

Navajo Nation Supreme Court
No. SC-CV-06-10 (2011)


John Doe BF (plaintiff) claimed that when he was 14–15 years old, his priest on the Navajo reservation gave him alcohol, sexually abused him, and threatened to expose him if he told anyone. Twenty years later, Doe sued the Diocese of Gallup, Baptist Order, and Guadalupe Order (defendants), claiming they assisted in the abuse by not reporting the priest after he was caught molesting children. The Diocese simply transferred the priest to other parishes where he continued having unsupervised access to children and did not implement any system to prevent further abuse. Doe explained his delay in bringing suit by submitting an affidavit stating that the latent psychological aspects of his injuries prevented him from discovering them and connecting them to the abuse until 2007. Doe also submitted journal articles finding that sexually abused Indian boys suffer acute withdrawal and isolation, in a culture that traditionally uses social integration to heal. The trial court ruled that limitations nonetheless barred Doe’s complaint. Doe appealed.

Rule of Law


Holding and Reasoning

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