Doe v. Hartford Roman Catholic Diocesan Corp. (USA)

The Connecticut Supreme Court affirmed a judgment for Jacob Doe, a pseudonym, who attended a parochial elementary school in the early 1980s and suffered damages for emotional injuries resulting from sexual abuse by F, a priest employed by the Hartford Roman Catholic Diocesan Corporation. Specifically, Doe alleged that the Church, after learning that F was an alcoholic and had sexually assaulted minors in the past, negligently assigned F to serve as the director of the school. Doe further alleged that, having made this assignment, the Church negligently failed to adequately supervise F or to warn others that F might be a danger to minors.

In writing about the need to extend statutes of limitations in childhood sexual abuse civil lawsuits, the court noted that Professor Marci Hamilton observed that “[l]egislation that eliminates the civil [statute of limitations] or includes a discovery rule is supported by various studies on the long-term effects of child molestation and the likely delay in disclosure. Researchers in various studies have found-specifically in men who were sexually abused as children-that long-term adaptation will often include sexual problems, dysfunctions or compulsions, confusion and struggles over gender and sexual identity, homophobia and confusion about sexual orientation, problems with intimacy, shame, guilt and self-blame, low self-esteem, negative self-images, increased anger, and conflicts with authority figures. There is also an increased rate of substance abuse, a tendency to deny and delegitimize the traumatic experience, symptoms of [p]ost [t]raumatic [s]tress [d]isorder, and increased probability of fear and depression for all victims. Often, it is not until years after the sexual abuse that victims experience these negative outcomes. As clinician Mic Hunter has observed: ‘Some of the effects of sexual abuse do not become apparent until the victim is an adult and a major life event, such as marriage or birth of a child, takes place. Therefore, a child who seemed unharmed by childhood abuse can develop crippling symptoms years later . . . .'” (Footnotes omitted.) M. Hamilton, “The Time Has Come for a Restatement of Child Sex Abuse.” (emphasis added).

Doe v. Hartford Roman Catholic Diocesan Corp.