Houllahan v. GelineauAnnotate this Case
The Supreme Court affirmed the decision of the superior court dismissing Plaintiffs' claims in favor of Defendants in accordance with Sup. Ct. R. Civ. P. 12(b)(6), holding that the trial court did not err in ruling that R.I. Gen. Laws 9-1-51 (the act), as amended, created a class of criminal actors beyond the scope of actual perpetrators as set forth in the act.
Plaintiffs filed separate actions alleging that they were sexually molested as minors by priests at the Roman Catholic Diocese of Providence. Plaintiffs claimed that Defendants' actions rose to the level of criminal aiding and abetting, thus constituting improper conduct. The trial justice granted Defendants' motions to dismiss all claims in all cases, holding that because Defendants were non-perpetrators, the actions were time-barred. The Supreme Court affirmed, holding (1) Defendants could not be found culpable as aiders or abettors; (2) even if Defendants' actions constituted a violation of a criminal statute, they were non-penetrators and the claims were time-barred; and (3) there was no other error.