John Doe v. the Catholic Diocese of El Paso and Msgr. Thomas Rowland, 362 S.W.3d 707

John Doe, born January 4, 1948, was sexually abused as a minor by Father Hay in 1963–1964 while Doe served as an altar boy at Our Lady of the Light in the Diocese of El Paso, with Msgr. Rowland as head priest.
Doe filed a June 2006 petition asserting torts including negligence, breach of fiduciary duty, intentional infliction of emotional distress, and vicarious liability; sued Diocese and Msgr. Rowland.
Doe’s accrual date was his eighteenth birthday (January 4, 1966); limitations generally run after accrual, with a five-year period for sexual assault claims, and a four-year or two-year period for other claims, depending on type.
Doe alleged tolling due to religious duress, unsound mind, and equitable estoppel; he asserted emotional/mental incapacity and psychological coercion prevented timely suit.
The trial court granted summary judgment on limitations; the appellate panel affirmed, focusing on whether issues of duress, unsound mind, or equitable estoppel precluded limitations as a matter of law.
Evidence included expert reports by Father Doyle, Dr. Benkert, and Dr. Foote; the court ultimately found no genuine issue of material fact on the tolling theories.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does religious duress toll limitations for Doe's claims?	Doe asserts duress disabled free will, delaying suit for decades.	No continuous or sufficient duress after majority; religious duress not legally tolling.	No genuine issue; duress tolling not supported.
Does unsound mind toll limitations in this case?	Doe was emotionally/mentally incapacitated during accrual period.	Evidence shows Doe was capable; no sustained incapacity during relevant period.	No unsound-mind tolling; insufficient evidence of incapacity.
Does equitable estoppel prevent asserting limitations?	Defendants’ conduct induced delay in filing.	No affirmative inducement to delay; statements cited do not trigger estoppel.	Equitable estoppel does not apply.

Pierce v. Estate of Haverlah, 428 S.W.2d 422 (Tex.Civ.App.--Tyler 1968) (duress tolls statute until duress ceases)
McNeil v. Lovelace, 529 S.W.2d 633 (Tex.Civ.App.--Fort Worth 1975) (duress framework; continuance requirement)
Grace v. Colorito, 4 S.W.3d 765 (Tex.App.--Austin 1999) (unsound mind tolling standard; capacity to sue)
Rendon v. Roman Catholic Diocese of Amarillo, 60 S.W.3d 389 (Tex.App.--Amarillo 2001) (equitable estoppel to toll limitations; need inducement)
Dean v. Frank W. Neal & Associates, Inc., 166 S.W.3d 352 (Tex.App.--Fort Worth 2005) (estoppel analysis for tolling; reasonable reliance)
King Ranch, Inc. v. Chapman, 118 S.W.3d 742 (Tex. 2003) (summary judgment standard; no-evidence standard context)
Doe v. Henderson Independent School Dist., 237 F.3d 631 (5th Cir. 2000) (unsound mind tolling in federal context; parallels)
Pierce v. Estate of Haverlah, 428 S.W.2d 422 (Tex.Civ.App.--Tyler 1968) (duress tolling principle referenced in opinion)