Tyson v. Tyson

727 P.2d 226, 107 Wash. 2d 72, 1986 Wash. LEXIS 1276
CourtWashington Supreme Court
DecidedOctober 30, 1986
Docket51908-1
StatusPublished
Cited by105 cases

This text of 727 P.2d 226 (Tyson v. Tyson) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tyson v. Tyson, 727 P.2d 226, 107 Wash. 2d 72, 1986 Wash. LEXIS 1276 (Wash. 1986).

Opinions

Durham, J.

The United States District Court for the Western District of Washington has certified the following question of state law to this court: Does the discovery rule, which tolls the statute of limitations until the plaintiff discovers or reasonably should have discovered a cause of [74]*74action, apply to intentional torts where the victim has blocked the incident from her conscious memory during the entire time of the statute of limitations? We answer the question in the negative.

The plaintiff here alleges that she was the victim of sexual abuse during her childhood. The parties have stipulated to the following facts: Plaintiff Nancy Tyson filed a complaint in the United States District Court for the Western District of Washington on August 26, 1983, alleging that her father, the defendant Dwight Robert Tyson, committed multiple acts of sexual assault upon her from 1960 through 1969. Plaintiff, whose birthdate is April 20, 1957, was between 3 and 11 years old at the time of the alleged acts, and was 26 years old at the time she filed the complaint.1 Plaintiff further alleged that the sexual assaults caused her to suppress any memory of the acts and that she did not remember the alleged acts until she entered psychological therapy during 1983. Plaintiff filed the complaint within 1 year of her recollection of the alleged acts.

Defendant has moved for summary judgment of dismissal in the federal court contending that, as a matter of law, plaintiff's claim is barred by the statutes of limitation in RCW 4.16.080 and 4.16.100.

We begin our analysis with a review of the statutes of limitation applicable to this action. RCW 4.16.080(2) provides that, in general, an action for personal injury must be brought within 3 years of the time the cause of action accrued. RCW 4.16.100(1) provides that an action for assault and battery must be brought within 2 years. If the person bringing the action is under the age of 18 years at the time the cause of action accrues, the statute of limitations is tolled until the person becomes 18 years old. RCW [75]*754.16.190. Under a literal reading of the limitation statutes, the cause of action accrues when the alleged wrongful act occurs. Ruth v. Dight, 75 Wn.2d 660, 665, 453 P.2d 631 (1969). Under these rules, the limitation period in this case expired at the latest on April 20, 1978, or 3 years after plaintiff's 18th birthday. Because plaintiff brought her action more than 8 years after her 18th birthday, her action would ordinarily be barred by the applicable statutes of limitation.

Plaintiff contends, however, that the discovery rule should apply to her complaint. The discovery rule provides that a statute of limitations does not begin to run until the plaintiff, using reasonable diligence, would have discovered the cause of action. U.S. Oil & Ref. Co. v. Department of Ecology, 96 Wn.2d 85, 92, 633 P.2d 1329 (1981).

Plaintiff claims that the alleged acts of sexual abuse caused her such emotional trauma that she repressed her memory of the events entirely. She asserts that years after the statute of limitations had expired, therapy triggered her knowledge of the abuse and her recognition that the abuse caused emotional problems she was experiencing as an adult. Plaintiff argues that it would be unfair to preclude her claim because she was unable to discover her cause of action during the applicable limitation period.

We recognize that child sexual abuse has devastating impacts on the victim. However, when a person claims emotional injuries resulting from an intentional tort which she has allegedly remembered only after the statute of limitations has expired, we must seriously consider the potential effects on our system of justice.

Statutes of limitation assist the courts in their pursuit of truth by barring stale claims. A number of evidentiary problems arise from stale claims. See generally Ruth, at 664-65. See also Note, Statutes of Limitations and the Discovery Rule in Latent Injury Claims: An Exception or the Law?, 43 U. Pitt. L. Rev. 501, 512-14 (1982). As time passes, evidence becomes less available. For example, the defendant might have had a critical alibi witness, only to [76]*76find that the witness has died or cannot be located by the time the action is brought. Likewise, witnesses who observed the plaintiff's behavior shortly after the alleged act may no longer be available. Physical evidence is also more likely to be lost when a claim is stale, either because it has been misplaced, or because its significance was not comprehended at the time of the alleged wrong. In addition, the evidence which is available becomes less trustworthy as witnesses' memories fade or are colored by intervening events and experiences. Old claims also are more likely to be spurious than new ones. "With the passing of time, minor grievances may fade away, but they may grow to outlandish proportions, too.” Ruth, at 665. Thus, stale claims present major evidentiary problems which can seriously undermine the courts' ability to determine the facts. By precluding stale claims, statutes of limitation increase the likelihood that courts will resolve factual issues fairly and accurately.

The discovery rule should be adopted only when the risk of stale claims is outweighed by the unfairness of precluding justified causes of action. U.S. Oil, at 93. In prior cases where we have applied the discovery rule, there was objective, verifiable evidence of the original wrongful act and the resulting physical injury. This increased the possibility that the fact finder would be able to determine the truth despite the passage of time, and thus diminished the danger of stale claims. For example, in Ruth v. Dight, supra, we adopted the discovery rule for a medical malpractice action arising from the presence of a foreign substance left inadvertently in a surgical wound. A hysterectomy was performed on the plaintiff in 1944. For a 22-year period following the surgery, plaintiff suffered recurrent abdominal pain. In 1966, plaintiff underwent an exploratory operation during which a sponge was found in her abdomen. After the sponge was removed, her recovery was normal. Ruth, at 662-63. Thus, there was empirical evidence of the occurrence of the alleged act (the initial surgery) and of the resulting harm (discovery of the [77]*77sponge). In Ohler v. Tacoma Gen. Hosp., 92 Wn.2d 507, 598 P.2d 1358 (1979), we applied the discovery rule to a products liability action against an incubator manufacturer for blindness due to excessive administration of oxygen to the plaintiff when she was a premature infant. There was evidence that plaintiff was placed in an incubator for about 16 days and given oxygen. Her blindness was an objective manifestation of the resulting injury. Ohler, at 508-09. Again, empirical evidence existed of the alleged event and resulting harm.

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Cite This Page — Counsel Stack

Bluebook (online)
727 P.2d 226, 107 Wash. 2d 72, 1986 Wash. LEXIS 1276, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tyson-v-tyson-wash-1986.