Mary Roe 1818 v. The Bishop of Charleston

CourtCourt of Appeals for the Fourth Circuit
DecidedMay 17, 2023
Docket22-1754
StatusUnpublished

This text of Mary Roe 1818 v. The Bishop of Charleston (Mary Roe 1818 v. The Bishop of Charleston) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mary Roe 1818 v. The Bishop of Charleston, (4th Cir. 2023).

Opinion

USCA4 Appeal: 22-1754 Doc: 41 Filed: 05/17/2023 Pg: 1 of 6

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 22-1754

MARY ROE 1818,

Plaintiff - Appellant,

v.

THE BISHOP OF CHARLESTON, a corporation sole; THE BISHOP OF THE DIOCESE OF CHARLESTON, in his official capacity,

Defendants - Appellees.

Appeal from the United States District Court for the District of South Carolina, at Charleston. Richard Mark Gergel, District Judge. (2:21-cv-00020-RMG)

Submitted: March 21, 2023 Decided: May 17, 2023

Before NIEMEYER, DIAZ, and THACKER, Circuit Judges.

Affirmed by unpublished per curiam opinion.

ON BRIEF: Lawrence E. Richter, Jr., THE RICHTER FIRM, LLC, Mt. Pleasant, South Carolina; James B. Richardson, Jr., Columbia, South Carolina, for Appellant. Richard S. Dukes, Jr., Charleston, South Carolina, Carmelo B. Sammataro, TURNER PADGET GRAHAM & LANEY, P.A., Columbia, South Carolina, for Appellees.

Unpublished opinions are not binding precedent in this circuit. USCA4 Appeal: 22-1754 Doc: 41 Filed: 05/17/2023 Pg: 2 of 6

PER CURIAM:

This case involves allegations of yet another reprehensible example of sexual abuse

by a Catholic priest, which allegedly took place between 1961 and 1966 to a young girl

born in 1959. Mary Roe 1818 (a pseudonym) alleged that a priest at St. John Catholic

Church in the Diocese of Charleston, South Carolina often came to her house and babysat

for her and her younger sister when Mary was 3 or 4 years old. She alleged that as the

priest lay “on the couch,” he “invit[ed] [her] and her sister to sit on his lap for a ‘pony

ride.’” In that process, as she alleged, the priest “placed [her] on his crotch, holding on to

[her] waist while moving her up and down on his erect penis.” While she never reported

the conduct, she nonetheless alleged that she suffered enormously from it with “guilt,

shame, loss of the enjoyment of her family and life generally, lack of self-worth, and

depression, with physical manifestations.”

Mary commenced this action in January 2021 against the Diocese of Charleston

(“The Bishop of Charleston, a corporation Sole, and the Bishop of the Diocese of

Charleston, in his official capacity”), alleging a range of torts relating to the Diocese’s

concealment and coverup, negligent monitoring and disciplining of priests, and breach of

a fiduciary relationship alleged to exist between the Diocese and its parishioners.

The Diocese answered Mary’s complaint and, following discovery, filed a motion

for summary judgment based on several grounds, including that the Diocese at the time

enjoyed charitable immunity under South Carolina law from all torts and that Mary’s

claims were barred by the applicable statutes of limitations, as her claims lapsed under

controlling principles “no later than August 5, 1980.” The district court granted the

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Diocese’s motion based on the doctrine of charitable immunity, finding it unnecessary, in

light of that ruling, to address the Diocese’s other arguments for summary judgment.

Mary filed this appeal, and, for the reasons given here, we affirm.

In 1914, the Supreme Court of South Carolina recognized that “[a] charitable

corporation is not liable to injuries, resulting from the negligent or tortious acts of a

servant, in the course of his employment, where such corporation has exercised due care

in his selection.” Lindler v. Columbia Hosp. of Richland Cnty., 81 S.E. 512, 512 (S.C.

1914) (emphasis added). The doctrine was expanded two years later when the court held

that charitable immunity extended to liability “for the torts of their superior officers and

agents as well as for those of their servants or employees, whether these be selected with

or without due care.” Vermillion v. Woman’s Coll. of Due West, 88 S.E. 649, 650 (S.C.

1916). The Vermillion court explained that a charitable corporation’s exemption from tort

liability rested “not upon the relation of the injured person to the charity, but upon grounds

of public policy, which forbids the crippling or destruction of charities . . . to compensate

one or more individual members of the public.” Id. It reasoned that it was “better for the

individual to suffer injury without compensation than for the public to be deprived of the

benefit of the charity.” Id. The doctrine was recognized and continued in cases thereafter,

including a case decided in favor of the Diocese in 1966. See Decker v. Bishop of

Charleston, 147 S.E.2d 264, 268 (S.C. 1966).

In the years that followed, however, in response to public criticism of the doctrine,

the South Carolina Supreme Court began to narrow it. In 1973, the court held that because

the early broad formulation of the scope of the immunity in Lindler, Vermillion, and Decker

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was unnecessary to the decision in those cases, the court could narrow the immunity to

exclude intentional torts, and it did so pursuant to reason and in the interest of justice. See

Jeffcoat v. Caine, 198 S.E.2d 258, 260 (S.C. 1973). Finally, in 1981, the court abolished

charitable immunity altogether. See Fitzer v. Greater Greenville South Carolina Young

Men’s Christian Ass’n, 282 S.E.2d 230, 232 (S.C. 1981) (holding that the “doctrine of

charitable immunity is abolished in its entirety”). A few years later, the court held that its

Fitzer holding applied “prospectively only.” Hupman v. Erskine Coll., 314 S.E.2d 314,

315 (S.C. 1984). Thus, during the period of 1961 to 1966, when the events of this case

allegedly took place, the immunity applied as articulated in Lindler and Vermillion.

In this case, the district court concluded first that there was no question as to the fact

that the Diocese was a charitable institution covered by South Carolina’s doctrine of

charitable immunity. Second, it concluded that the doctrine, as articulated in Lindler and

Vermillion, applied fully during the period of the events alleged by Mary. And finally, it

found particularly instructive that the immunity had been held to apply in particular to a

case similar to this one. In Doe v. Diocese of Charleston, the plaintiff alleged that,

beginning in 1959 or 1960, he had been abused while a minor student at an elementary

school owned by the Diocese, asserting claims like those in this case, including outrage,

breach of fiduciary duty, negligent supervision, and fraudulent concealment. The Doe

court held that all the plaintiff’s claims were barred by charitable immunity, explaining:

It is undisputed that the events in question occurred before the abolition of the Doctrine of Charitable Immunity in 1981, and even before the Supreme Court’s prospective limitations on its application, such as the intentional torts exception in 1973. Accordingly, at the time of the events in question, it was the law of South Carolina that charities were immune as to all tort liability.

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Doe, No. 02-CP-10-0770, 2003 WL 25456994 (S.C. Ct. Com. Pl. Jan. 10, 2003) (emphasis

added).

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Related

Decker v. Bishop of Charleston
147 S.E.2d 264 (Supreme Court of South Carolina, 1966)
Hupman v. Erskine College
314 S.E.2d 314 (Supreme Court of South Carolina, 1984)
Jeffcoat v. Caine
198 S.E.2d 258 (Supreme Court of South Carolina, 1973)
Vermillion v. Woman's College of Due West
88 S.E. 649 (Supreme Court of South Carolina, 1916)
Lindler v. Columbia Hospital
81 S.E. 512 (Supreme Court of South Carolina, 1914)

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