Doe v. New London Cmty. Sch. Dist.
Annotate this CasePlaintiff, who attended school in the New London Community School District, was fourteen years old when Gina Sisk, a teacher who also served as Plaintiff’s track coach, began to engage in improper sexual conduct toward Plaintiff. The alleged abuse occurred in the early 2000s. In 2012, Plaintiff filed a petition against the District asserting several tort claims. Defendants filed a motion for summary judgment, arguing that Plaintiff’s claims were barred by the statute of limitations in the pre-2007 Iowa Municipal Tort Claims Act (IMTCA). The district court denied Defendants’ motions. At issue before the Supreme Court was whether a discovery rule was available to Plaintiff. The Supreme Court reversed, holding (1) the common law discovery rule does not apply to claims under the pre-2007 IMTCA; (2) the limitations provision in Iowa Code 614.8A does not apply to individuals who were fourteen years or older when the alleged sexual abuse occurred; and (3) the absence of a discovery rule in the pre-2007 IMTCA does not violate the Iowa Constitution’s equal protection clause.
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