Cummings v. Bartlett

CourtDistrict Court, D. New Hampshire
DecidedJune 19, 1997
DocketCV-94-183-SD
StatusPublished

This text of Cummings v. Bartlett (Cummings v. Bartlett) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cummings v. Bartlett, (D.N.H. 1997).

Opinion

Cummings v. Bartlett CV-94-183-SD 06/19/97 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Mary Lou Cummings

v. Civil No. 94-183-SD

Warren A. Bartlett

OPINION AND ORDER

In this diversity action, plaintiff Mary Lou Cummings

asserts several tort claims against defendant Warren A. Bartlett

based upon Bartlett's alleged sexual abuse of her when she was a

child.

Following its denial of defendant's motion for summary

judgment, the court ruled that the statute of limitations issue

should be determined by the court prior to trial. This Opinion

and Order addresses the relevant factual and legal issues raised

in the course of a one-day evidentiary hearing, at which

testimony was heard from the plaintiff and a certified

psychologist specializing in adult survivors of childhood sexual

abuse. The expert witness was relied upon by both parties. Background

Mary Lou Cummings was born on October 17, 1962, and moved

with her family to Lancaster, New Hampshire, when she was in the

third grade.1 She alleges that between the years 1972 and 1978

she was repeatedly sexually abused by Warren Bartlett, a close

friend of her family's. The abuse started when she was about ten

and occurred most freguently when she was between the ages of 11

and ll^.2

The abuse would occur when plaintiff paid overnight visits

to the Bartlett home while her parents were away. Bartlett would

enter the room where Cummings was sleeping, get into bed with

her, and fondle her genital areas and rub against her. Bartlett,

a photographer, also allegedly sexually assaulted plaintiff in

the darkroom of his studio.

Cummings told no one of the abuse until September of 1992,

when she received a telephone call from her mother informing her

that her sister remembered being sexually abused by Bartlett as a

child. This information spurred plaintiff to acknowledge to

another for the first time that she had been sexually abused.

1Cummings presently resides in Cincinnati, Ohio.

2The court has assumed for the purposes of this Opinion and Order that the abuse in fact occurred. Of course, the ultimate determination is for the jury.

2 After telling her mother, Cummings entered therapy for the first

time to discuss the abuse. Sh e also began suffering

emotional distress in the form of nightmares, anger, and other

symptoms. Cummings filed this litigation on April 11, 1994.

Defendant denies that he ever sexually abused plaintiff, and

contends that, at most, plaintiff spent only one week overnight

in his home during the time period alleged. He also contends

that between 1973 and late 1991 he and his wife had cordial

relations with the plaintiff and that on the occasion of the last

visit the plaintiff had suggested to the defendant a joint skiing

outing for the winter of 1992.

Further relevant facts will be developed in the course of

this Opinion and Order.

Discussion

Applying an early version of the New Hampshire statute of

limitations. Revised Statutes Annotated (RSA) 508:4, I, the court

has previously determined that the governing limitations period

is six years, which had long since expired by the time the

plaintiff filed her complaint in 1994.3 In addition, although

plaintiff was a child at the time of the abuse, the two-year

3The earlier statute was applied because plaintiff's cause of action arose prior to a 1986 amendment which would have reduced the period to three years.

3 limitations period that applied once she attained the age of

majority had also expired. See RSA 508:8. Plaintiff wishes to

invoke the common-law discovery rule to toll the limitations

period until September of 1992, when she first acknowledged to

another that she had been sexually abused.

Under the discovery rule, "'a cause of action does not

accrue until the plaintiff discovers or, in the exercise of

reasonable diligence, should have discovered both the fact of his

injury and the cause thereof.'" McCollum v. D'Arcv, 138 N.H.

285, 287, 638 A.2d 797, 798 (1994) (guoting Heath v. Sears,

Roebuck & C o ., 123 N.H. 512, 523-24, 464 A.2d 288, 294 (1983)).

The rule reguires that the court weigh the parties' competing

interests and consider "'the unfairness which would result to a

plaintiff blamelessly ignorant of her injury whose action would

be cut off before she was aware of its existence.'" Rowe v. John

Deere, 130 N.H. 18, 22-23, 533 A.2d 375, 377 (1987) (guoting

Shilladv v. Elliot Community Hosp., 114 N.H. 321, 323, 320 A.2d

637, 638 (1974)) .

Many courts have struggled with the issue of whether, and to

what extent, a victim of childhood sexual abuse can take

advantage of the discovery rule. Successful invocation of the

discovery rule depends in part on the extent to which the victim

remembered the abuse. In one leading New Hampshire case,

4 McCollum, supra, 138 N.H. at 286-288, 638 A.2d at 798, the court

held that the discovery rule could be used by a plaintiff who had

repressed all memory of abuse perpetrated by her parents until 34

years later when she began experiencing flashbacks that were

triggered by her attendance at a therapy workshop on child abuse.

The court reasoned that since the abuse and its causal connection

to the plaintiff's injuries were not discovered until decades

after the abuse occurred, the plaintiff's interest in being

compensated for her injuries outweighed any competing interest

the defendant may have had in avoiding litigation. Id. at 288,

638 A.2d at 799.

In another leading case, Conrad v. Hazen, 140 N.H. 249, 665

A.2d 372 (1995), the plaintiff did not repress the memory of a

childhood sexual assault, but did not identify the assault as

rape until she entered counseling as an adult. The court ruled

that the controlling guestion was whether the plaintiff's

original injury was "'sufficiently serious to apprise the

plaintiff that a possible violation of [her] rights had taken

place.'" Id. at 252, 665 A.2d at 375 (guoting Rowe v. John

Deere, 130 N.H. 18, 22, 533 A.2d 375, 377 (1987)). If the

original injury was of such character, the discovery rule would

not apply. At the time of her assault, Conrad experienced pain

and physical injury and emotionally felt "devastated," as well as

5 "dirty, sick, and scared." Id. at 253, 665 A.2d at 375.

Although hazarding that such injuries "appeared" to indicate that

the discovery rule could not be applied, the court ultimately

chose to remand the case to the trial court to determine the

guestion in the first instance. Id. at 253, 665 A.2d at 376.

Cummings's case falls somewhere in between the facts of

McCollum and Conrad. Unlike McCollum, Cummings did not repress

all memory of the events constituting the abuse. Instead,

Cummings engaged in a defensive mechanism known as "adaptive

denial," Tr. 79, which only somewhat affected her memory of the

events in guestion, but wholly precluded her from realizing that

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Related

Shillady v. Elliot Community Hospital
320 A.2d 637 (Supreme Court of New Hampshire, 1974)
Heath v. Sears, Roebuck & Co.
464 A.2d 288 (Supreme Court of New Hampshire, 1983)
Sinclair v. Brill
857 F. Supp. 132 (D. New Hampshire, 1994)
Bowen v. Eli Lilly & Co.
557 N.E.2d 739 (Massachusetts Supreme Judicial Court, 1990)
Armstrong v. Lamy
938 F. Supp. 1018 (D. Massachusetts, 1996)
Rowe v. John Deere
533 A.2d 375 (Supreme Court of New Hampshire, 1987)
McCollum v. D'Arcy
638 A.2d 797 (Supreme Court of New Hampshire, 1994)
Conrad v. Hazen
665 A.2d 372 (Supreme Court of New Hampshire, 1995)

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