Cohane v. Home Missioners of Am.

CourtSupreme Court of North Carolina
DecidedJanuary 31, 2025
Docket278A23
StatusPublished

This text of Cohane v. Home Missioners of Am. (Cohane v. Home Missioners of Am.) is published on Counsel Stack Legal Research, covering Supreme Court of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cohane v. Home Missioners of Am., (N.C. 2025).

Opinion

IN THE SUPREME COURT OF NORTH CAROLINA

No. 278A23

Filed 31 January 2025

GREGORY COHANE

v. THE HOME MISSIONERS OF AMERICA d/b/a GLENMARY HOME MISSIONERS, ROMAN CATHOLIC DIOCESE OF CHARLOTTE, NC, and AL BEHM

On discretionary review pursuant to N.C.G.S. § 7A-31 of the decision of a

divided panel of the Court of Appeals, 290 N.C. App. 378 (2023), reversing an order

entered on 27 October 2021 by Judge Daniel Kuehnert in Superior Court,

Mecklenburg County, and remanding the case. Heard in the Supreme Court on 18

September 2024.

White & Stradley, PLLC, by J. David Stradley and Leto Copeley, for plaintiff- appellee.

Troutman Pepper Hamilton Sanders LLP, by Joshua D. Davey and Mary K. Grob, for defendant-appellant Roman Catholic Diocese of Charlotte, NC; and Steven B. Epstein for defendant-appellant the Home Missioners of America d/b/a Glenmary Home Missioners.

Sam McGee for CHILD USA, amicus curiae.

Jeff Jackson, Attorney General, by Ryan Y. Park, Solicitor General, Nicholas S. Brod, Deputy Solicitor General, and Orlando L. Rodriguez, Special Deputy Attorney General, for the State of North Carolina, amicus curiae.

Nelson Mullins Riley & Scarborough, LLP, by Lorin J. Lapidus, G. Gray Wilson, Denise M. Gunter, and D. Martin Warf; and Bell, Davis & Pitt, P.A., by Kevin G. Williams, for Young Men’s Christian Association of Northwest North Carolina d/b/a Kernersville Family YMCA, amicus curiae. COHANE V. HOME MISSIONERS OF AM.

Opinion of the Court

EARLS, Justice.

This is a companion case to McKinney v. Goins, No. 109PA22-2 (N.C. Jan. 31,

2024), also announced today. There, we held that the revival provision of the SAFE

Child Act facially comports with the North Carolina Constitution. Here, we again

address the revival provision. The issue before us is whether section 4.2(b) of the

SAFE Child Act, which “revives any civil action for child sexual abuse otherwise time-

barred” by the three-year statute of limitations, resuscitates claims against direct

abusers as well as those who allegedly enabled the abuse. We hold that it does.

One background feature of North Carolina tort law is that a plaintiff can be

made whole by recovering from the individual who directly harmed them as well as

those who specially contributed to the harm. For example, a plaintiff hurt by a

negligent truck driver can sue the truck driver directly, as well as the company who

employed, supervised, or hired that person with knowledge of their negligent driving

practices. A second background feature is that North Carolina has not recognized a

distinct “child sexual abuse” tort. Instead, child sexual abuse victims may bring civil

actions under traditional common law torts, such as assault or battery. That means

that traditional tort principles apply to common law actions to recover for child sexual

abuse.

Against this backdrop, the unanimous SAFE Child Act opened a window for

adults who experienced sexual abuse as children to recover for that abuse under tort

-2- COHANE V. HOME MISSIONERS OF AM.

law, even if the statute of limitations on their claims had since passed. See An Act to

Protect Children From Sexual Abuse and to Strengthen and Modernize Sexual

Assault Laws (SAFE Child Act), S.L. 2019-245, § 4.2(b), 2019 N.C. Sess. Laws 1231,

1235. That narrow window provided that, for two years only, “this section revives any

civil action for child sexual abuse otherwise time-barred under G.S. 1-52.” Id. In turn,

N.C.G.S. § 1-52 is the three-year statute of limitations that applies to negligence and

other types of personal injury torts. See Misenheimer v. Burris, 360 N.C. 620, 625

(2006) (noting that common law negligence actions are limited by N.C.G.S. § 1-52).

The issue here is whether the General Assembly meant to distinguish between

abusers who personally harmed the plaintiff and those organizations, institutions,

and parties that employed or supervised the abuser or otherwise condoned, ratified,

or facilitated the abuse (enablers). Defendants would have us hold not only that the

revival provision distinguished between the two types of potential defendants but also

that it authorized suits against abusers and not against enablers, in contravention of

background tort law principles. We conclude that such a distinction does not follow

from the plain text of the provision, nor does it find support in the SAFE Child Act or

related statutory provisions read as a whole.

Because the revival of “any civil action for child sexual abuse otherwise time-

barred under G.S. 1-52” really means any such action, consistent with applicable tort

law principles, we hold that claims against abusers and enablers are equally revived.

The decision of the Court of Appeals is affirmed.

-3- COHANE V. HOME MISSIONERS OF AM.

I. Background

A. The SAFE Child Act

The SAFE Child Act was passed unanimously by the General Assembly and

signed into law by the Governor. Its purpose according to its title was to “protect

children from sexual abuse and to strengthen and modernize sexual assault laws.”

2019 N.C. Sess. Laws at 1231.

Part IV of the Act made a number of changes extending civil statutes of

limitations. For example, the Act extended the time period by which a plaintiff could

file a civil action “for claims related to sexual abuse” that occurred while that person

was a minor. Id. § 4.1, 2019 N.C. Sess. Laws at 1234. Ordinarily, when a minor

experiences a personal injury, the statute of limitations for their civil action tolls until

they turn eighteen years old. See N.C.G.S. § 1-17(a) (2023). Section 4.1 of the Act

extended that tolling period for claims “related to sexual abuse” that occurred while

the person was a minor until that person turns twenty-eight years old, giving a

prospective plaintiff many more years to bring such suits. See SAFE Child Act § 4.1,

2019 N.C. Sess. Laws at 1234.

The Act also granted plaintiffs of all ages a second bite at the civil liability

apple where the underlying abuse results in a new criminal conviction: “[A] plaintiff

may file a civil action within two years of the date of a criminal conviction for a related

felony sexual offense against a defendant for claims related to sexual abuse suffered

while the plaintiff was under 18 years of age.” Id. § 4.2(a), 2019 N.C. Sess. Laws at

-4- COHANE V. HOME MISSIONERS OF AM.

1235. The Act further clarified that the statutes of limitations for assault, battery,

false imprisonment, and other personal injury tort claims under N.C.G.S. § 1-52(5),

(16), and (19) are curtailed to the extent they conflict with those two new sections. Id.

In addition to those forward-looking changes extending the statutes of

limitation, the Act also offered one backward-looking change. It resurrected already

time-barred civil claims if they were brought in a narrow period of time:

Effective from January 1, 2020, until December 31, 2021, this section revives any civil action for child sexual abuse otherwise time-barred under G.S. 1-52 as it existed immediately before the enactment of this act.

Id. § 4.2(b), 2019 N.C. Sess. Laws at 1235.1 This so-called “revival provision” gave

new life to plaintiff Gregory Cohane’s claims for injury.

B. Mr. Cohane’s Civil Action

Mr. Cohane makes the following allegations in his complaint, which we accept

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Delconte v. State
329 S.E.2d 636 (Supreme Court of North Carolina, 1985)
Wilson v. McLeod Oil Co., Inc.
398 S.E.2d 586 (Supreme Court of North Carolina, 1990)
White v. Consolidated Planning, Inc.
603 S.E.2d 147 (Court of Appeals of North Carolina, 2004)
Custom Molders, Inc. v. American Yard Products, Inc.
463 S.E.2d 199 (Supreme Court of North Carolina, 1995)
Spruill v. Lake Phelps Volunteer Fire Department, Inc.
523 S.E.2d 672 (Supreme Court of North Carolina, 2000)
Misenheimer v. Burris
637 S.E.2d 173 (Supreme Court of North Carolina, 2006)
Turlington v. McLeod
374 S.E.2d 394 (Supreme Court of North Carolina, 1988)
Bridges v. Parrish
742 S.E.2d 794 (Supreme Court of North Carolina, 2013)
Wilkie v. City of Boiling Spring Lakes
809 S.E.2d 853 (Supreme Court of North Carolina, 2018)
Smith Chapel Baptist Church v. City of Durham
517 S.E.2d 874 (Supreme Court of North Carolina, 1999)
In re the Foreclosure of the Deed of Trust of Vogler Realty, Inc.
722 S.E.2d 459 (Supreme Court of North Carolina, 2012)
Kasten v. Saint-Gobain Performance Plastics Corp.
179 L. Ed. 2d 379 (Supreme Court, 2011)
Doe v. Diocese Raleigh
776 S.E.2d 29 (Court of Appeals of North Carolina, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Cohane v. Home Missioners of Am., Counsel Stack Legal Research, https://law.counselstack.com/opinion/cohane-v-home-missioners-of-am-nc-2025.