Supreme Court of Pennsylvania adopted “notice inquiry” approach to discovery rule when deciding whether applicable statute of limitations period was tolled.

The plaintiff and her family were members of St. Leo, a parish located within the Altoona-Johnstown Diocese, and the plaintiff attended the affiliated Catholic school. From 1974 to 1981, a priest assigned to St. Leo’s sexually assaulted the plaintiff. The plaintiff did not report the abuse until 2006. In 2014, the District Attorney of Cambria County issued a referral to the Office of the Attorney General regarding reports of sexual abuse occurring within the Altoona-Johnstown Diocese. On March 1, 2016, the investigating grand jury issued a report, finding that priests victimized hundreds of children and that the Diocese was aware of these actions. 

The plaintiff filed her initial complaint on June 20, 2016. The Diocese filed a motion for judgment on the pleadings that raised the statute of limitations as a defense. In its motion, the Diocese contended that, as the last assault occurred in 1981, the limitations period had long expired. The Diocese relied on a line of cases stemming from Meehan v. Archdiocese of Philadelphia, 870 A.2d 912 (Pa. Super. 2005), and argued that the plaintiff knew the primary causes of her injuries (i.e., the abuse by the priest) and thus, the discovery rule was inapplicable to any secondary causes (i.e., the conduct of the Diocese). 

While the trial court granted the Diocese’s motion, the Superior Court of Pennsylvania reversed.

On appeal, the Supreme Court of Pennsylvania reversed the order of the Superior Court and reinstated the trial court’s dismissal of the case. The Supreme Court adopted the “inquiry notice” approach to the discovery rule. This approach “‘t[ies] commencement of the limitations period to the actual or construction knowledge of at least some form of significant harm and of a factual cause linked to another’s conduct, without the necessity of notice of the full extent of the injury, the fact of actual negligence, or precise cause.’” The Supreme Court ruled that the statute of limitations began to run when the plaintiff was last assaulted, as she knew of her injury and the cause of this injury. As to the identification of secondary causes of her injuries, the Supreme Court ruled that the plaintiff “was on inquiry notice regarding other potentially liable actors, including the Diocese,” and should have investigated these other causes during the limitations period. 
 

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