## Facts

- Jane Doe worked for the Roman Catholic Bishop of Sacramento (the Diocese) beginning in 1989 and remained employed for nearly two decades.
- Doe, a devout Catholic parishioner, placed significant trust in parish clergy and allowed two priests, Fathers Jose Luis Urbina and Gerardo Beltran, close access to her family, including regular visits and counseling.
- Doe alleged that, in the late 1980s, Urbina and Beltran molested two of her young sons.
- The priests later left the country: one after pleading guilty to child-molestation charges unrelated to Doe’s sons, and the other after being accused by another family of child molestation.
- Doe alleged the Diocese concealed or misrepresented the priests’ misconduct and the reasons for their departures, preventing her from discovering her children’s abuse and the Diocese’s role.
- Doe alleged she learned of her sons’ molestation only in 2007–2008, when her sons disclosed it.
- In 2008, Doe sued the Diocese for fraud and negligence (including negligent retention, supervision, and failure to warn), seeking damages for emotional distress and related harms.

## Issues

1. Whether Doe’s fraud and negligence claims were barred by applicable statutes of limitations.
2. Whether California’s delayed discovery rule postponed accrual until 2007–2008, when Doe learned her sons were molested.
3. Whether Doe had inquiry notice decades earlier—when she knew the priests left the country amid molestation accusations—triggering a duty to investigate and starting the limitations periods.
4. Whether alleged fraudulent concealment by the Diocese tolled limitations despite Doe’s awareness of molestation accusations and the priests’ flight.

## Decision

- The Court of Appeal affirmed the judgment sustaining the Diocese’s demurrer without leave to amend and dismissing the complaint.
- The court held Doe’s claims accrued almost 20 years earlier because she had a duty of inquiry when she knew the priests fled due to child-molestation accusations.
- The court concluded the delayed discovery rule did not postpone accrual until Doe’s later confirmation that her own sons were victims.
- The court held alleged concealment did not toll limitations where Doe’s own allegations established notice of facts sufficient to prompt investigation.
- The court assumed, without deciding, that Doe’s causes of action had substantive merit, resolving the case solely on limitations grounds.

## Legal Principles

- Under California’s discovery rule, a claim accrues when a plaintiff has reason to suspect injury and a wrongful cause, not when the plaintiff learns all facts or obtains confirmation.
- Once on inquiry notice, a plaintiff must conduct a reasonable investigation and is charged with knowledge that such an investigation would have revealed.
- Inquiry notice is assessed objectively: whether known circumstances would prompt a reasonable person to investigate possible wrongdoing.
- Fraudulent concealment does not toll limitations where the plaintiff is already aware of facts sufficient to arouse suspicion and trigger a duty to investigate.

## Conclusion

The court held Doe’s fraud and negligence claims against the Diocese were untimely because her knowledge that priests with close access to her children fled the country amid child-molestation accusations triggered an objective duty to investigate decades earlier, starting the statutes of limitations notwithstanding later disclosure of her sons’ specific abuse.


Doe v. Roman Catholic Bishop of Sacramento, 189 Cal. App. 4th 1423, 117 Cal. Rptr. 3d 597 (Ct. App. 2010)