Doe v. Archdiocese of Saint Paul & Minneapolis
2012 Minn. LEXIS 307
| Minn. | 2012Background
- Doe alleges childhood sexual abuse by Fr. Adamson in 1980–1981; Dioceses knew of Adamson’s history and reassigned him rather than publicizing it.
- Doe repressed memories of the abuse and claims recovery in 2002 tolled the six-year limitations period.
- Doe filed suit on April 24, 2006, asserting negligence, negligent supervision/retention, vicarious liability, fraud, and fraudulent non-disclosure.
- The District Court excluded Doe’s repressed-memory expert testimony under Frye-Mack, granting summary judgment for the Dioceses.
- Court of Appeals reversed, suggesting possible admissibility under Rule 702; Minnesota Supreme Court held it inadmissible due to lack of foundational reliability, affirming summary judgment.
- The Court held Doe’s claims untimely and affirmed the Dioceses’ summary judgment; the ruling centers on Rule 702 foundational reliability rather than general acceptance under Frye-Mack.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of repressed-memory evidence | Doe’s experts support tolling via repressed-memory theory | Memory-repression theory is not generally accepted or reliably foundational | inadmissible under Rule 702 for lack of foundational reliability |
| Timeliness of claims without repressed-memory evidence | Repressed-memory tolling delays accrual | No tolling under statute; claims untimely | Claims untimely under both delayed discovery and fraud statutes |
Key Cases Cited
- Frye v. United States, 293 F.2d 1013 (D.C.Cir.1923) (establishes the general-acceptance requirement for novel scientific theories)
- State v. Mack, 292 N.W.2d 764 (Minn.1980) (framework for evaluating novel scientific evidence in Frye-Mack context)
- Goeb v. Tharaldson, 615 N.W.2d 800 (Minn.2000) (foundational reliability and general-acceptance analysis for expert testimony)
- MacLennan v. State, 702 N.W.2d 219 (Minn.2005) (distinguishes syndrome evidence from physical-science evidence; Frye-Mack not always applicable)
- Jacobson v. $55,900 in U.S. Currency, 728 N.W.2d 510 (Minn.2007) (case applying Rule 702 foundational reliability in non-DNA context; case-by-case admissibility analysis)
- Toombs v. Daniels, 361 N.W.2d 801 (Minn.1985) (objective discovery standard for fraud statute)