Narrative Opinion Summary
This case examines the appropriate statute of limitations for claims of childhood sexual abuse by state employees, focusing on the conflict between R.C. 2305.111(C) and R.C. 2743.16(A). The appellant, a former juvenile correctional facility resident, alleges sexual abuse by state employees and challenges the dismissal of her claims based on the two-year limitations period for actions against the state. The Court of Claims and the Tenth District Court of Appeals previously ruled her claims time-barred, but the appellant argues for the 12-year period under R.C. 2305.111(C) to apply, citing the discovery rule and constitutional concerns under the Equal Protection Clause. The court clarifies that the 12-year statute applies to childhood sexual abuse claims, including those against state actors, due to legislative intent and statutory construction rules favoring the specific, later-enacted statute. The court avoids ruling on constitutional grounds, opting instead for statutory interpretation. The judgment is reversed and remanded for further proceedings to assess claim validity under the discovery rule, as the appellant asserts she did not discover the abuse until after the enactment of S.B. 17.
Legal Issues Addressed
Conflict Between R.C. 2305.111 and R.C. 2743.16(A)subscribe to see similar legal issues
Application: The more specific and later-enacted statute, R.C. 2305.111(C), prevails over the older and more general R.C. 2743.16(A) in the context of childhood sexual abuse claims.
Reasoning: According to Ohio statutory construction rules, a more specific and later-enacted statute prevails in conflicts. R.C. 2305.111(C), enacted in 2006, specifically addresses claims related to childhood sexual abuse and is thus applicable over the broader R.C. 2743.16(A), which is older and more general.
Constitutional Avoidance Doctrinesubscribe to see similar legal issues
Application: The court chose to resolve the case based on statutory interpretation rather than addressing Watkins's constitutional argument regarding the Equal Protection Clause.
Reasoning: The court refrains from addressing Watkins's constitutional argument, emphasizing that cases should be resolved on non-constitutional grounds when possible.
Discovery Rule in Childhood Sexual Abuse Casessubscribe to see similar legal issues
Application: The discovery rule allows the statute of limitations to begin when the victim discovers the abuse, potentially extending the filing period beyond the victim's age of majority.
Reasoning: The court previously established in Ault v. Jasko that the discovery rule applies to childhood sexual abuse claims, meaning the one-year statute of limitations begins when the victim recalls or discovers the abuse, allowing for possible tolling.
Retroactive Application of R.C. 2305.111(C)subscribe to see similar legal issues
Application: R.C. 2305.111(C) can apply retroactively to claims that have not yet expired before the enactment of S.B. 17, but the timing of the claim's discovery is crucial for its applicability.
Reasoning: R.C. 2305.111(C) allows for retroactive application, but only for claims where the prior statute of limitations had not expired before S.B. 17 took effect.
Statute of Limitations for Childhood Sexual Abuse under R.C. 2305.111(C)subscribe to see similar legal issues
Application: The 12-year statute of limitations applies to claims of childhood sexual abuse, including those against state actors, overriding the general two-year limit for civil actions against the state.
Reasoning: The applicable statute of limitations for claims of childhood sexual abuse by state employees is determined to be the 12-year limit under R.C. 2305.111(C), which specifically addresses such claims, rather than the two-year limit under R.C. 2743.16(A) for civil actions against the state.