Archbishop of Washington v. Doe

Summary

The court held that the 2017 statutory period for filing child sexual abuse claims against non-perpetrator defendants was an ordinary statute of limitations, not a statute of repose. Because expiration of an ordinary limitations period does not create a vested right to freedom from liability, the 2023 Act could retroactively eliminate that period without violating Maryland's constitutional protections for vested property rights. The court further held that retroactively reviving a remedy previously barred by a limitations period is subject to heightened rational-basis review, and the Act satisfies that standard.