Facts
- In June 1977, James Turner, age sixteen, alleged that Father Alfred Willis, a priest assigned to a parish under the Diocese’s authority, sexually assaulted him in a motel room in Albany, New York, following Turner’s brother’s ordination.
- Turner alleged Willis later attempted another assault at Turner’s parents’ home in Derby, Vermont.
- Turner claimed long-term psychological and emotional harm from the abuse.
- Turner alleged the Diocese had prior information about Willis and negligently hired, trained, supervised, and retained him, leading to the abuse and its consequences.
- Turner sued the Diocese in 2004 asserting negligence-based claims (including negligent supervision).
Issues
- Whether the trial court properly granted judgment as a matter of law (JMOL) setting aside the jury’s finding that the action was time-barred under the discovery-rule limitations framework for child sexual abuse claims.
- Whether the First Amendment barred a negligent-supervision claim against a diocese as an impermissible intrusion into ecclesiastical matters.
- Whether the trial court erred in granting a mistrial in the first trial and imposing monetary sanctions on the Diocese.
- Whether it was error to seat a juror who was a member of the Diocese.
Decision
- The Vermont Supreme Court reversed the judgment and remanded for further proceedings.
- The Court held the trial court erred in granting JMOL on the statute-of-limitations issue because the record permitted a reasonable jury to find the claim untimely.
- The Court rejected the Diocese’s categorical First Amendment immunity argument, concluding that negligent-supervision claims may be adjudicated using neutral principles of tort law without resolving religious doctrine.
- The Court addressed the mistrial/sanctions and juror-selection issues as part of its appellate review and remanded rather than affirming the post-trial judgment.
Legal Principles
- Under Vermont’s discovery-rule framework for child sexual abuse claims, the limitations period turns on when the plaintiff knew or reasonably should have known of the abuse, resulting harm, and the defendant’s responsibility; where reasonable factfinders can differ, the issue is for the jury.
- A court may not set aside a jury’s statute-of-limitations finding via JMOL if there is evidence on which a reasonable jury could reach that finding.
- The First Amendment does not categorically bar tort claims against religious institutions; civil courts may apply neutral, generally applicable tort standards to claims such as negligent supervision so long as adjudication does not require deciding religious doctrine, church polity, or ecclesiastical questions as such.
- Juror affiliation with a party does not automatically require disqualification, but voir dire must be sufficient to identify and address potential bias.
Conclusion
The court reinstated the jury’s determination that the claim was time-barred by reversing the trial court’s JMOL, while also holding that negligent supervision claims against a diocese are not automatically foreclosed by the First Amendment when they can be resolved through neutral tort principles; the case was remanded for further proceedings.