Florida Law Weekly – October 2, 2020

R.R. v. New Life Community Church of CMA, Inc. – Supreme Court of Florida

In this case, the Supreme Court of Florida concluded that negligence and respondeat superior claims against an employer for sexual abuse accrue at the time of injury in a case where the alleged abuse occurred when the Plaintiff was a minor. Plaintiffs alleged that the sexual abuse they experienced as children by the Defendant was connected to and facilitated by his employment. As a result, Plaintiffs brought negligence and respondeat superior claims against the Defendant Church as well. The Church’s motion for summary judgment was granted because Plaintiffs’ claims against them accrued at the time of injury and were therefore untimely. The Supreme Court of Florida affirmed the 2nd DCA’s holding that unless otherwise stated within a statute, a cause of action accrues when its last element occurs.