Sheehan v. Oblates of St. Francis de Sales

Father Francis Norris, a priest from the Oblates of St. Francis (the Oblates), was a teacher at the Salesianum School. James Sheehan (plaintiff) was a student. In 1962, Norris sexually abused Sheehan. Norris’s conduct was criminal under 1962 law. Sheehan did not report the abuse. Norris died in 1985. In 2007, Delaware passed the Child Victim’s Act, which repealed the civil statute of limitations for child sexual-abuse claims and created a two-year window during which previously time-barred claims could be brought. Sheehan sued the Salesianum School and the Oblates, alleging that their negligent and intentional actions caused Sheehan’s injuries. At trial, documentary evidence proved the Oblates were aware that Norris sexually abused children before placing him at the Salesianum School. The court ruled against Sheehan, holding that (1) the Salesianum School was not negligent; (2) although the Oblates were negligent, that negligence was not the proximate cause of Sheehan’s injuries; and (3) the act did not revive intentional tort claims. Sheehan appealed, arguing that the trial court erred by denying his intentional tort claims against the Salesianum School. The Oblates cross-appealed, arguing that (a) the act was unconstitutional because it revived an expired cause of action; and (b) the age of Sheehan’s claim impeded the Oblates’ ability to gather evidence and witnesses to mount a defense.