Doe v. El Dorado Union High School District CA3, C089531

Two former El Dorado Union High School District students alleged repeated sexual assaults by a former teacher while they were 16–17; the teacher was later arrested and charged.
Plaintiffs sued the District in 2018 for sexual harassment and negligence; suits were consolidated.
The District had a regulation (invoking Gov. Code § 935) requiring written presentation of claims to the District within six months of accrual; plaintiffs never presented a claim.
The trial court granted the District’s motion for judgment on the pleadings, dismissing the suits as time-barred for failure to present the required claim.
The Legislature amended Gov. Code § 935 in 2018 to prohibit local prefiling claim requirements for childhood sexual abuse claims, and in 2019 amended Code Civ. Proc. § 340.1 to revive certain childhood sexual-assault claims that would otherwise have been barred by claim-presentation deadlines.
The Court of Appeal reversed, holding the 2019 amendment to Code Civ. Proc. § 340.1 revived appellants’ claims and allowed them to proceed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a local school district could lawfully impose a 6‑month claim‑presentation requirement for childhood sexual‑assault claims under Gov. Code § 935	§ 340.1 “governs” these claims, so § 935 does not authorize a local claim‑presentation rule	§ 935 permits local rules for claims excepted by § 905, so the District validly adopted a 6‑month rule	Not necessary to resolve; court reversed on statutory revival grounds (2019 § 340.1)
Whether the 2018 amendment to Gov. Code § 935 (prohibiting local claim rules for childhood sexual abuse) applies retroactively to bar enforcement of the District’s regulation	The 2018 amendment is retroactive and prevents enforcement	Statutes are presumed prospective; the “declaratory” label does not overcome the presumption against retroactivity	Not reached as dispositive; decision rested on 2019 revival statute
Whether the 2019 amendment to Code of Civil Procedure § 340.1 revived claims previously barred by a claim‑presentation deadline	The 2019 amendment expressly revives claims not litigated to finality that would have been barred as of 1/1/2020 and allows them to be filed within three years	District contested applicability	Held: Yes — the 2019 amendment revives appellants’ claims; judgment reversed

Quigley v. Garden Valley Fire Protection Dist., 7 Cal.5th 798 (describes Government Claims Act framework and claim‑presentation purpose)
Shirk v. Vista Unified School Dist., 42 Cal.4th 201 (held governmental claim‑presentation requirement applies to injury‑to‑person claims prior to legislative change)
McWilliams v. City of Long Beach, 56 Cal.4th 613 (explains purpose of prefiling claim requirement to permit investigation and settlement)
McClung v. Employment Development Dept., 34 Cal.4th 467 (discusses presumption against statutory retroactivity)
Coats v. New Haven Unified School Dist., 46 Cal.App.5th 415 (similar reversal based on 2019 amendment to Code Civ. Proc. § 340.1)