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Doe v. Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints

Citations: 837 F. Supp. 2d 1145; 2011 U.S. Dist. LEXIS 87290; 2011 WL 3439163Docket: Case No. 1:09-cv-351-BLW

Court: District Court, D. Idaho; August 5, 2011; Federal District Court

Narrative Opinion Summary

In this case, the plaintiff, a former Boy Scout, alleges sexual abuse by a scout leader and asserts claims against the Boy Scouts and associated entities. The legal proceedings involve several motions relating to the plaintiff’s Second Amended Complaint, which includes claims of sexual abuse, emotional distress, and fraud. The Boy Scout Defendants moved to strike or dismiss certain claims, arguing they exceeded the scope of permissible amendments and lacked specificity under pleading standards established by Twombly and Iqbal. The court denied these motions, finding that the amendments were permissible and the claims met the necessary legal standards. The court further addressed the statute of limitations, applying Idaho's three-year period for fraud claims, which begins upon discovery of the alleged fraud. The court concluded that the plaintiff's claims were timely. Additionally, the court ruled on discovery motions, compelling the plaintiff to disclose medical records relevant to his claims while denying requests deemed overly broad. The court's decisions focus on allowing the plaintiff to present evidence while maintaining procedural and substantive legal standards. Ultimately, the case continues with the plaintiff's claims intact, pending further proceedings.

Legal Issues Addressed

Amendment of Complaints and Scope of Leave

Application: Doe's restructuring of a fraud claim into two more specific claims did not exceed the scope of the court's permission to amend, as the order did not specify restrictions.

Reasoning: The Court denied the Boy Scout Defendants’ Motion to Strike for three reasons: (1) the Court's order granting leave to amend did not specify any restrictions, allowing for a more precise evaluation of the fraud claims.

Discovery and Relevance under Rule 26(b)(1)

Application: The court grants the LDS Defendants' motion to compel in part, requiring Doe to disclose medical records relevant to his claims, indicating a balance between relevance and overbroad requests.

Reasoning: The LDS Defendants' motion is partially granted for records pertaining to conditions at issue but denied for irrelevant and overly broad requests for complete medical history.

Federal Rule of Civil Procedure 12(b)(6) and Extrinsic Evidence

Application: The court finds that Doe's extrinsic documents are inappropriate for judicial notice under Rule 12(b)(6), and opts not to convert the motion to dismiss into a summary judgment motion.

Reasoning: Doe’s extrinsic documents are deemed inappropriate for judicial notice, as they do not qualify as records from administrative bodies or facts not subject to reasonable dispute.

Pleading Standards under Federal Rules

Application: The court evaluates whether Doe's claims meet the pleading requirements of plausibility and specificity as per Rule 8(a) and Rule 9(b), supported by Twombly and Iqbal standards.

Reasoning: The Boy Scout Defendants argue that the claims fail to meet the Iqbal/Twombly standards for pleading, specifically under Rules 8(a) and 9(b) which require particularity in fraud allegations.

Statute of Limitations for Fraud Claims

Application: The court applies Idaho's three-year statute of limitations for fraud, considering the discovery rule, and finds Doe's claims timely as he discovered the fraud in 2007 or 2008.

Reasoning: Doe asserts he only discovered the alleged fraud in 2007 or 2008, suggesting his claims are timely if the three-year statute applies.