R.R. v. New Life Community Church of CMA, Inc.

Summary

The court held that accrual of minors’ negligence and respondeat superior claims is governed by the statutory limitations framework, which generally starts the limitations period when the last element of the cause of action occurs. Because the Legislature adopted a tolling provision for minors rather than a general delayed-accrual rule, courts may not create an additional common-law accrual rule based solely on minority. The court also declined to extend the delayed-discovery rule to the petitioners’ negligence and respondeat superior claims and approved the judgment below.