Latest Case: R.R. v. New Life Community Church of CMA, Inc. (Personal Injury)

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R.R. v. New Life Community Church of CMA, Inc.

Docket: SC18-962

Opinion Date: October 1, 2020

Judge: Muniz

Areas of Law: Personal Injury

In this child sexual abuse case concerning the separation of powers and the proper role of courts in applying statutes of limitations the Supreme Court held that courts cannot go beyond the statutory framework and adopt a special, judge-made rule to govern the accrual of tort claims where the would-be plaintiff is a minor. Petitioners alleged that Daniel Heffield sexually abused them as children. Petitioners filed the underlying lawsuit against New Life Community Church, Daniel's employer at the time of the alleged abuse, and other defendants, alleging negligence claims and a respondeat superior claim. Respondents (other than Daniel) moved for summary judgment, arguing that Petitioners' claims were untimely. The trial court entered summary judgment for Respondents, concluding that Petitioners' claims accrued at the time of injury and therefore were untimely. The court of appeal affirmed. On appeal, Petitioners argued that the accrual of their claims were governed by the judge-made delayed accrual rule that the Supreme Court applied in Hearndon v. Graham, 767 So. 2d 1179 (Fla. 2000). The Supreme Court affirmed, holding (1) the statutory framework leaves no room for supplemental common law accrual rules; and (2) the Hearndon decision did not apply to delay the accrual of Petitioners' claims.