R.L., Plaintiff-Respondent v. Kenneth Voytac, Defendant-Appellant

Summary

The Supreme Court of New Jersey held that the statute of limitations for child sexual abuse claims is governed by an objective reasonable‑discovery standard and that the accrual date is the earlier of the plaintiff’s actual discovery or the date a reasonable victim would have discovered the causal link. Applying that standard, the Court found the cause of action accrued by the time of the plaintiff’s February 2002 conversation with a co‑worker, and remanded for a new hearing on both accrual and tolling. The Court also held that the trial court erred in its tolling analysis and that duress was insufficient to toll the limitations period.