Jane Doe v. New London Community School District
2014 Iowa Sup. LEXIS 73
| Iowa | 2014Background
- Jane Doe alleged a New London school teacher/coach sexually abused her beginning in summer 2000 when she was 14 through roughly 2006; she filed suit against the teacher and the school district in March 2012 asserting negligence, respondeat superior, and related claims against the district.
- The district moved for summary judgment under the pre-2007 Iowa Municipal Tort Claims Act (IMTCA), Iowa Code § 670.5 (pre-2007), arguing Doe’s claims were time-barred.
- Doe relied on the common-law discovery rule (claims timely within two years of discovery of injury and cause) and, alternatively, on Iowa Code § 614.8A (four-year discovery-based tolling for child sexual-abuse claims), and also raised an equal-protection challenge if those rules were unavailable.
- The district court denied summary judgment; the Supreme Court granted interlocutory review. The alleged misconduct and all relevant conduct predated the 2007 amendment to § 670.5.
- The Supreme Court analyzed (1) whether the pre-2007 IMTCA incorporated the discovery rule, (2) whether § 614.8A applied (definition of “child”), and (3) whether denying a discovery rule violated Iowa Const. art. I, § 6 (equal protection).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the pre-2007 IMTCA incorporates the common-law discovery rule | Discovery rule applies so limitations run from discovery of injury and cause, making Doe’s 2012 suit timely | Pre-2007 § 670.5 is a statute of creation triggered by the injury date and contains no accrual language or discovery rule | The discovery rule does not apply to pre-2007 IMTCA claims; prior precedent controlling (Montgomery, Farnum, etc.) |
| Whether Iowa Code § 614.8A (child sexual-abuse discovery tolling) applies | § 614.8A tolling (4 years from discovery) should apply to child sexual-abuse claims, saving Doe’s claim | § 614.8A’s definition of “child” (as interpreted) limits it to persons under 14, and Doe was 14 when abuse began, so it does not apply | § 614.8A does not apply because precedent (Doe v. Cherwitz and follow-ups) defines “child” as under 14; Doe (age 14) cannot use § 614.8A |
| Whether denying the discovery rule to IMTCA claimants violates Iowa Const. art. I, § 6 (equal protection) | Differential treatment of municipal v. private defendants is irrational and denies equal protection | Legislature rationally may subject municipalities to different (shorter/structured) limitations because of limited resources, budgeting, and public-interest considerations | No equal protection violation; rational-basis test satisfied—legislative differences for municipal defendants are rational |
| Whether, given stare decisis and legislative acquiescence, the Court should reshuffle prior statutory interpretations | Plaintiff urged reinterpretation to reach a fairer result | Defendant relied on longstanding precedent and legislative inaction as supporting current interpretations | Court declined to overturn controlling precedents (Montgomery, Farnum, Cherwitz line) and left any change to the legislature |
Key Cases Cited
- Montgomery v. Polk Cnty., 278 N.W.2d 911 (Iowa 1979) (pre-2007 IMTCA is a statute of creation and does not incorporate the discovery rule)
- Farnum v. G.D. Searle & Co., 339 N.W.2d 392 (Iowa 1983) (reaffirming Montgomery and rejecting discovery rule under IMTCA)
- Miller v. Boone Cnty. Hosp., 394 N.W.2d 776 (Iowa 1986) (invalidated six-month filing rule where notice not given; held chapter 614 governs limitations applicable after Miller)
- Callahan v. State, 464 N.W.2d 268 (Iowa 1990) (contrasted IMTCA with statutes using “accrual”; reaffirmed discovery rule in accrual statutes but not in IMTCA)
- Doe v. Cherwitz, 518 N.W.2d 362 (Iowa 1994) (construed “child” in § 614.8A to mean persons under age 14)
- Perkins ex rel. Perkins v. Dallas Ctr.-Grimes Cmty. Sch. Dist., 727 N.W.2d 877 (Iowa 2007) (legislature did not intend to incorporate tolling provisions into pre-2007 IMTCA)
- Rucker v. Humboldt Cmty. Sch. Dist., 737 N.W.2d 292 (Iowa 2007) (reiterated Perkins; Miller affected only six-month no-notice bar)
- Frideres v. Schiltz, 540 N.W.2d 261 (Iowa 1995) (applied discovery-rule principles in other contexts; cited Cherwitz on § 614.8A interpretation)