Nussbaum v. Steinberg

In October 1988, Hedda Nussbaum (plaintiff) filed a cause of action against her former romantic partner, Joel Steinberg (defendant). Nussbaum alleged that between 1978 and 1987, Steinberg had committed multiple torts against her, including battery, assault, and intentional infliction of emotional distress. Nussbaum filed the action after Steinberg was incarcerated for the death of their daughter. Steinberg moved for summary judgment. Steinberg argued that Nussbaum was barred by the statute of limitations from filing the suit because most of the torts listed in the complaint occurred more than one year before the action was filed. In response, Nussbaum argued that the severe psychological and physical abuse Steinberg had inflicted on her during the relationship caused her to suffer insanity. Therefore, Nussbaum claimed that because she suffered insanity, she was entitled to a tolling of the statute of limitations under Civil Practice Laws and Rules § 208. The court held a hearing to determine the applicability of § 208. At the hearing, Nussbaum testified that Steinberg had caused her to suffer severe physical, emotional, and psychological abuse, which led her to develop psychological disorders. Nussbaum introduced a police videotape into evidence to show that, at the time of their daughter’s death, almost every part of Nussbaum’s body had been mutilated. Additionally, Nussbaum introduced expert testimony from her treating psychiatrist and a psychological-trauma expert. The experts testified that Nussbaum had suffered prolonged abuse, had severe psychotic disorders, and was unable to make any decisions about her own life or function in society because of the trauma Steinberg had inflicted. Steinberg introduced expert testimony from a retired forensic psychiatrist who stated that Nussbaum had never lost her ability to make decisions or leave the relationship. However, the psychiatrist also admitted that he had little knowledge of or experience in psychological trauma and domestic violence.