## Facts

- In 1970, a 15-year-old parishioner was employed as a rectory housekeeper by the parish priest at a Roman Catholic church in Illinois.
- The plaintiff alleged the priest raped and sexually abused her over several years and used threats tied to church discipline and spiritual consequences to deter disclosure.
- The plaintiff alleged she later reported the abuse to another priest and the bishop; she was told the bishop would do nothing and was pressured to forgive the abuser through religious ritual and admonitions.
- In 1995, the plaintiff filed suit against the priest, the diocese, and the parish asserting multiple theories arising from childhood sexual abuse.
- Defendants sought dismissal and summary judgment, asserting the claims were barred by the two-year personal-injury limitations period and a childhood sexual abuse statute of repose.
- The trial court dismissed the action as untimely; the appellate court reinstated the plaintiff’s claims (counts I–XI) on equitable estoppel and legal-disability grounds; defendants obtained review.

## Issues

1. Whether the plaintiff’s claims (counts I–XI) were barred by the applicable statutes of limitations and the childhood sexual abuse statute of repose.
2. Whether equitable estoppel prevented defendants from asserting limitations and repose defenses based on alleged threats, coercion, and pastoral influence.
3. Whether the plaintiff’s allegations established a “legal disability” that tolled limitations.
4. Whether a fiduciary relationship, without specific allegations of post-abuse misrepresentation or concealment inducing delay, could support equitable estoppel.

## Decision

- The court reversed the appellate court and upheld dismissal of counts I–XI as untimely.
- The court held the claims were filed decades after the alleged abuse and outside both the limitations period and the statute of repose.
- The court held equitable estoppel did not apply because the complaint did not plead post-abuse misrepresentations or concealment by any defendant intended to induce delayed filing, nor reasonable reliance causing delay.
- The court rejected the “fiduciary relationship alone” estoppel theory, noting it was raised for the first time on review and, in any event, did not eliminate the traditional elements of equitable estoppel.
- The court held the plaintiff did not plead a qualifying “legal disability” under Illinois tolling statutes; severe emotional or spiritual effects were insufficient absent statutory markers of legal incapacity.

## Legal Principles

- Statutes of limitations and a statute of repose bar claims filed outside their prescribed periods unless a recognized tolling doctrine is properly pleaded and proven.
- Equitable estoppel against a limitations defense requires specific defendant conduct (affirmative representation or concealment) calculated to induce delay, plus actual and reasonable reliance resulting in late filing.
- Coercive or abusive conduct occurring during the abuse period, without pleaded post-abuse inducement directed at delaying litigation, is insufficient to establish equitable estoppel.
- A fiduciary or pastoral relationship does not, by itself, estop a defendant from asserting time bars; the traditional elements of estoppel remain required.
- “Legal disability” tolling is narrowly defined and generally does not include psychological, emotional, or spiritual impairment absent statutory legal incapacity.

## Conclusion

The Illinois Supreme Court held that historic clergy-abuse claims filed decades after the alleged conduct were barred by limitations and repose, and that neither equitable estoppel nor legal-disability tolling applied without well-pleaded, post-abuse inducement to delay suit or a statutorily recognized legal incapacity.


Parks v. Kownacki, 193 Ill. 2d 164, 737 N.E.2d 287 (Ill. 2000)