Ouellette v. Beaupre, No. 19-2069 (1st Cir. 2020)
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The First Circuit vacated the decision of the district court granting summary judgment for Defendants and dismissing Plaintiff's 42 U.S.C. 1983 action on the grounds that Plaintiff's claims were time barred, holding that there was no basis for summary judgment on the record.
Plaintiff filed suit against the City of Biddeford, Captain Norman Gaudette with the Biddeford Police Department (BPD), and Chief of Police Roger Beaupre, alleging that Gaudette sexually abused him as a teenager in the later 1980s and that the City and Baupre were deliberately indifferent to Gaudette's violation of his constitutional rights when Plaintiff reported the abuse. Defendants argued that the suit was barred by the statute of limitations. In response, Plaintiff asserted that his claims did not accrue until 2015, when he learned that the BPD and Baupre allegedly knew of at least one other report of Gaudette sexually abusing a minor that pre-dated Plaintiff's experience. The district court granted summary judgment for Defendants. The First Circuit reversed, holding (1) a reasonable jury could find that Plaintiff had no duty to diligently investigate his claims against Defendants before 2015; and (2) therefore, the district court erred in concluding as a matter of law that Plaintiff's claims accrued at the time of his injury in the late 1980s.
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