DOE v. SAINT JOSEPH'S CATHOLIC CHURCH

870 S.E.2d 365, 313 Ga. 558
CourtSupreme Court of Georgia
DecidedMarch 8, 2022
DocketS21G0549
StatusPublished
Cited by18 cases

This text of 870 S.E.2d 365 (DOE v. SAINT JOSEPH'S CATHOLIC CHURCH) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DOE v. SAINT JOSEPH'S CATHOLIC CHURCH, 870 S.E.2d 365, 313 Ga. 558 (Ga. 2022).

Opinion

313 Ga. 558 FINAL COPY

S21G0549. DOE v. SAINT JOSEPH’S CATHOLIC CHURCH et al.

COLVIN, Justice.

In December 2018, Philip Doe filed suit against Saint Joseph’s

Catholic Church, Archbishop Wilton Gregory, and the Archdiocese

of Atlanta (collectively, “the Church”), asserting various tort claims

based in part on childhood sexual abuse Doe allegedly suffered while

serving as an altar boy at Saint Joseph’s in the late 1970s.1 The trial

court granted the Church’s motion to dismiss, ruling, in pertinent

part, that Doe’s “non-nuisance tort claims” were barred by the

applicable two-year statute of limitation, OCGA § 9-3-33,2 and could

1 Doe’s amended complaint included three categories of claims against

the Church: common-law and statutory claims for public nuisance (Counts 1 and 2); “non-nuisance tort claims” for negligent failure to train, supervise, and monitor (Count 3), negligent retention (Count 4), failure to warn (Count 5), failure to provide adequate security (Count 6), respondeat superior (Count 7), breach of fiduciary duty (Count 8), and fraudulent misrepresentation and concealment (Counts 9 and 10); and a claim for Racketeer Influenced and Corrupt Organizations (“RICO”) Act violations (Count 11). 2 In relevant part, OCGA § 9-3-33 says that, “[e]xcept as otherwise

provided in this article, actions for injuries to the person shall be brought within two years after the right of action accrues[.]” By operation of law, however, the limitation period for Doe’s claims against the Church for torts not be tolled for fraud by OCGA § 9-3-96, which provides that

[i]f the defendant or those under whom he claims are guilty of a fraud by which the plaintiff has been debarred or deterred from bringing an action, the period of limitation shall run only from the time of the plaintiff’s discovery of the fraud.

A divided panel of the Court of Appeals affirmed. See Doe v. Saint

Joseph’s Catholic Church, 357 Ga. App. 710, 712-715 (1) (a)-(c) (850

SE2d 267) (2020). We granted the Church’s petition for certiorari,

asking

[w]hether the trial court erred in granting [the Church’s] motion to dismiss [Doe’s] non-nuisance tort claims based on the determination that the complaint failed to allege facts that could support the application of OCGA § 9-3-96 sufficient to toll the statute of limitation as to the non- nuisance tort claims.[3]

For the reasons set forth below, we affirm in part and reverse in part

committed while he was a minor were tolled until he reached the age of majority in the 1980s. See OCGA § 9-3-90 (b) (“[I]ndividuals who are less than 18 years of age when a cause of action accrues shall be entitled to the same time after he or she reaches the age of 18 years to bring an action as is prescribed for other persons.”). 3 The Court of Appeals also affirmed the trial court’s dismissal of the

nuisance and RICO Act claims (Counts 1, 2, and 11). See Doe, 357 Ga. App. at 715-717 (1) (d), (2). We do not address those rulings, as our certiorari question was limited to what the Court of Appeals referred to as “Doe’s non-nuisance tort claims (Counts 3 through 10).” Id. at 712 (1) (a). 2 the judgment of the Court of Appeals. Although the trial court

correctly determined that Doe’s claim seeking to hold the Church

vicariously liable under the doctrine of respondeat superior was

time-barred, the court erred in concluding at the motion-to-dismiss

stage that Doe could not introduce evidence of fraud within the

framework of his complaint sufficient under OCGA § 9-3-96 to toll

the limitation period as to his claims of negligent training and

supervision, negligent retention, failure to warn and provide

adequate security, breach of fiduciary duty, and fraudulent

misrepresentation and concealment.

1. Doe filed suit against the Church on December 20, 2018.

According to Doe’s amended complaint, the Church employed Father

J. Douglas Edwards as a priest to oversee Saint Joseph’s day-to-day

operations from 1976 to 1981. In that role, Father Edwards was

responsible for training altar boys and supervising them during

Mass, regular meetings, practices, and overnight trips. Doe alleged

that he served as an altar boy under Father Edwards’s supervision

for approximately three years in the late 1970s, from the age of 12

3 to 15. According to Doe, Father Edwards sexually molested him

eight to ten times between 1976 and 1978, during the time period

when he was serving as an altar boy.

Doe alleged that, before Father Edwards abused him, the

Church knew that Father Edwards and other priests belonging to

Archdioceses across the country had a history of sexually abusing

children. Nevertheless, according to Doe, the Church engaged in a

“systematic cover-up effort” to conceal the danger that the priests

posed to minor parishioners like Doe, even as they encouraged Doe

and other minor parishioners to serve as altar boys under the care

and supervision of such priests.

Doe further alleged that on August 9 and 16, 2018, Archbishop

Gregory issued public statements apologizing for “sexual abuse by

Church leaders of children, young people and those over whom they

exercised authority,” the failure of Church leaders “to protect others

from such damaging and deviant behavior,” and the Church’s

disbelief and neglect of those who “came forward to tell Church

officials of their torment.” According to Doe, however, he “had no

4 knowledge that [the Church] knew that [Father] Edwards had been

accused of molesting children” until November 6, 2018, when the

Church “formally acknowledged th[e] culture of sexual abuse by its

priests” by releasing a list of priests “credibly accused of sexual

abuse of a minor.” This list included Father Edwards, who had died

in 1997, and showed that, in the 14 years preceding his transfer to

Saint Joseph’s, Father Edwards had served at nine different

Catholic churches and taken a year-long leave of absence.4

The Church moved to dismiss the amended complaint, arguing

that Doe’s claims were time-barred pursuant to OCGA § 9-3-33. In

response, Doe argued that OCGA § 9-3-96 tolled the limitation

period until November 2018, when the Church disclosed its

knowledge of credible sexual-abuse allegations against Father

Edwards.

Following briefing and a hearing, the trial court rejected Doe’s

tolling argument and granted the Church’s motion to dismiss. The

4 Additional specific allegations pertinent to Doe’s claims are discussed

below. 5 trial court concluded that, even assuming the Church was in a

confidential relationship with Doe and had fraudulently concealed

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

Related

WILLIAM DOE v. ARCHDIOCESE OF ATLANTA
Court of Appeals of Georgia, 2026
MARCIA ANITA JOHNSON v. JIMMY W. JOHNSON
Court of Appeals of Georgia, 2026
Jackson v. Bobbitt
S.D. Georgia, 2025
DETHOMAS INVESTMENTS, LLC v. LMRK PROPCO, LLC
Court of Appeals of Georgia, 2025
STATHAM v. QUANG
915 S.E.2d 864 (Supreme Court of Georgia, 2025)
Prodigies Child Care Management, LLC v. Cotton
317 Ga. 371 (Supreme Court of Georgia, 2023)
Elkin King v. Forrest King, Jr.
69 F.4th 738 (Eleventh Circuit, 2023)
King v. King, Jr
888 S.E.2d 166 (Supreme Court of Georgia, 2023)
Philip Doe v. Saint Joseph's Catholic Church
Court of Appeals of Georgia, 2022
DOUGLAS COE v. PROSKAUER ROSE LLP
314 Ga. 519 (Supreme Court of Georgia, 2022)
MILLER v. ALLI
M.D. Georgia, 2022

Cite This Page — Counsel Stack

Bluebook (online)
870 S.E.2d 365, 313 Ga. 558, Counsel Stack Legal Research, https://law.counselstack.com/opinion/doe-v-saint-josephs-catholic-church-ga-2022.