The Second Circuit ruled today in Edwardo v. The Roman Catholic Bishop of Providence that sexual misconduct committed by a Catholic priest from another state during a work-related trip does not establish the jurisdiction of Rhode Island parish under New York law.
The case is about a man who was tragically sexually abused and exploited between 1978 and 1984, when they were 12 to 17 years old, by a now-deceased priest from Rhode Island. The plaintiff sued the Roman Catholic Bishop of Providence, a church corporation in North Providence, and a retired bishop for various torts based on the defendants’ alleged role in enabling the abuse. The U.S. District Court for the Southern District of New York dismissed the lawsuit for lack of personal jurisdiction, finding that New York’s long-arm statute did not permit the court to exercise personal jurisdiction over the defendants. The plaintiff appealed to the Second Circuit.
Why sue in New York in the first place? New York had a window that allowed sexual abuse claims that Rhode Island did not. Rhode Island extended its civil statute of limitations in 2019 for child sexual abuse cases. Under the new law, victims generally have until they reach the age of 53 to file a lawsuit against their abuser or the institution that enabled the abuse. This is a significant extension from the previous limit, which allowed victims only up to 7 years after turning 18 to file a lawsuit. It is unclear how the timing of this played out for this case but the case was originally filed in Rhode Island and dismissed as time-barred. So New York was the only option plaintiffs had and that mean hoping New York would assert jurisdiction.
