Doe v. McCoy, 297 Neb. 321

Plaintiffs filed a 2016 tort complaint (using pseudonyms “Jane Doe” and “John Doe”) alleging sexual abuse of Jane Doe by defendant McCoy from ~1991–1999 when she was a minor.
Jane Doe was born in 1985 and turned 21 on September 21, 2006; John Doe asserted derivative loss-of-consortium claims based on Jane Doe’s allegations.
Defendant moved to dismiss for (1) statute-of-limitations bar and (2) failure to sue in real names under Neb. Rev. Stat. § 25-301; plaintiffs later provided their real names confidentially but had not obtained prior court permission to proceed anonymously.
District court dismissed the complaint, holding the action was time barred under §§ 25-207 and 25-213 (tolled until age 21, then four-year limitations) with the limitations having run in 2010.
Plaintiffs argued Neb. Rev. Stat. § 25-228 (enacted 2012, extending child-sexual-assault civil claims to 12 years after age 21) made the 2016 filing timely; the district court rejected that argument as § 25-228 could not revive an already completed statutory bar.
The Nebraska Supreme Court affirmed dismissal on statute-of-limitations grounds and did not reach the pseudonym question as the limitations ruling was dispositive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 25-228 (2012) extends the limitations period so the 2016 suit is timely	§ 25-228’s "notwithstanding any other provision of law" shows legislature intended a 12-year post-21 limitation to apply, making the 2016 filing timely	Prior statutes (§§ 25-207 & 25-213) had already produced a complete bar in 2010; legislature cannot resurrect extinguished claims; § 25-228 does not apply retroactively to already-barred claims	Held: § 25-228 does not revive claims already time-barred when it was enacted; suit was barred; dismissal affirmed
Whether plaintiffs could proceed anonymously under § 25-301 and related common-law rules	Plaintiffs sought to proceed under pseudonyms citing sensitivity of sexual-abuse allegations	Defendant argued actions must be brought in real names; plaintiffs failed to obtain pre-filing court approval to proceed anonymously	District court disallowed anonymity; Supreme Court did not decide because limitations ruling was dispositive

Givens v. Anchor Packing, 237 Neb. 565 (congressional amendment cannot resurrect claims extinguished under prior limitations; vested bar is protected)
Schendt v. Dewey, 246 Neb. 573 (limitations period in effect at filing governs; legislature may not deprive a defendant of a completed statutory bar)
Rasmussen v. State Farm Mut. Auto. Ins. Co., 278 Neb. 289 (loss-of-consortium is derivative of primary plaintiff’s viable claim)
Irwin v. West Gate Bank, 288 Neb. 353 (appellate courts need not decide issues unnecessary to disposition)