Jones v. Cattaraugus-Little Valley Central School District, No. 22-1442 (2d Cir. 2024)
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In the United States Court of Appeals for the Second Circuit, the appellant, Brittany Jones, claimed she was sexually abused by a teacher between 2009 and 2011, when she was a high school student. She brought her claims under the Child Victims Act (CVA) of New York, which revived time-barred claims of child sexual abuse victims, and provided a two-year window from August 14, 2019 to August 14, 2021 for the filing of such claims. However, Jones filed her suit four months before the commencement of this window. The United States District Court for the Western District of New York, in a summary judgment, ruled in favor of the school district, holding that Jones's premature filing created a valid statute-of-limitations defense for the school district.
This decision was appealed and the key question before the appellate court was whether the six-month waiting period created by the CVA was a statute of limitations. The appellate court concluded that neither the text of the CVA nor any precedent from New York courts provided clear guidance on this issue. Given the significant state policy interests implicated by the CVA, the appellate court decided to certify the question to the New York Court of Appeals: whether the six-month waiting period for claims under the CVA establishes a statute of limitations, a condition precedent to bringing suit, or some other affirmative defense. The court reserved its decision on the appeal pending the response from the New York Court of Appeals.
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