Devon Reeg v. Murray Bert Keel, Jr., 174 So. 3d 309

Reeg worked for Dr. Keel from 2003–2005 (ages 19–21) and alleges repeated sexual touching and digital penetration occurring during employment. She reported at least one incident to coworkers in March 2005.
Reeg left employment in 2005; Hurricane Katrina later destroyed the office.
She sought mental-health treatment years later and was diagnosed with PTSD in July 2013. She claims she did not connect the PTSD to Keel’s conduct until that diagnosis.
Reeg filed suit in March 2014 asserting assault, battery, intentional and negligent infliction of emotional distress, and breach of an employment contract.
Keel moved to dismiss based on statutes of limitations (one-year for assault/battery/intentional infliction and breach; three-year catch-all for negligent infliction). The trial court dismissed; Reeg appealed.
The Court of Appeals affirmed, holding neither the savings statute (unsound mind/infancy) nor the discovery rule tolled the limitations periods.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statute of limitations tolled under savings statute for unsound mind/infancy	Reeg: psychological incapacity following abuse prevented timely filing; equitable tolling applies	Keel: no evidence Reeg was mentally incompetent; she managed ordinary affairs; infancy tolling ended at 21	Court: Infancy tolled until age 21 but no evidence of unsound mind; savings statute not applicable beyond infancy
Whether discovery rule delays accrual (latent injury)	Reeg: PTSD diagnosis in 2013 established she did not discover connection until then, so accrual occurred at diagnosis	Keel: alleged acts were physical and known when committed; no latent injury so discovery rule inapplicable	Court: Acts were not latent; she reported incidents in 2005 and was capable of perceiving injury; discovery rule does not apply
Whether physical sexual acts permit delayed accrual due to psychological realization	Reeg: psychological comprehension of abuse is necessary for accrual	Keel: physical acts are objectively discoverable at the time of occurrence	Court: For physical sexual acts by an adult, accrual is at occurrence; later psychological realization does not create latent injury
Whether dismissal on statute-of-limitations grounds was proper	Reeg: tolling doctrines save her claims	Keel: claims are time-barred under governing statutes	Court: Dismissal affirmed; claims barred for failure to file within statutory periods

Jones v. Fluor Daniel Servs. Corp., 32 So. 3d 417 (Miss. 2010) (one-year limitations applies to intentional infliction of emotional distress)
Brumfield v. Lowe, 744 So. 2d 383 (Miss. Ct. App. 1999) (standard for "unsound mind" under savings statute)
Shippers Express v. Chapman, 364 So. 2d 1097 (Miss. 1978) (managing ordinary affairs test for mental incapacity)
Anderson v. R&D Foods, Inc., 913 So. 2d 394 (Miss. Ct. App. 2005) (infancy tolling until age twenty-one)
Lawler v. Gov’t Emps. Ins. Co., 569 So. 2d 1151 (Miss. 1990) (infancy tolling principle)
Taylor v. Gen. Motors Corp., 717 So. 2d 747 (Miss. 1998) (statute of limitations begins at twenty-first birthday for infants)
Doe v. Roman Catholic Diocese of Jackson, 947 So. 2d 983 (Miss. Ct. App. 2006) (discovery rule requires reasonable diligence and applies to latent injuries)
Wayne Gen. Hosp. v. Hayes, 868 So. 2d 997 (Miss. 2004) (discovery rule focus is when plaintiff discovers or should have discovered actionable injury)
PPG Architectural Finishes, Inc. v. Lowery, 909 So. 2d 47 (Miss. 2005) (discovery rule limited to latent injury or disease)
Rockwell v. Preferred Risk Mut. Ins. Co., 710 So. 2d 388 (Miss. 1998) (purpose of savings statute to protect those unable to assert rights)