Summary
This Sixth Circuit opinion addresses whether a Title IX claim brought by a former student against Ohio State University for sexual abuse by a diving coach was time-barred. The court held that Ohio’s two-year personal-injury statute of limitations applies to Title IX claims, rejecting the plaintiff's argument that a longer twelve-year limitations period for child sex-abuse claims should govern. Because the plaintiff filed her complaint more than six years after turning eighteen, well beyond the two-year accrual window, the court affirmed the district court's grant of summary judgment dismissing the claim as time-barred.
Topics
Practice areas
Questions Presented
- Whether the district court applied the correct statute of limitations to Pryor’s Title IX claim.
Holdings
- Ohio’s two‑year personal‑injury limitations period, Ohio Rev. Code §2305.10(A), applies to Title IX claims, and Pryor’s claim is time‑barred.
Key quotations
“The sole question before us is whether the district court applied the proper limitations period to Pryor’s Title IX claim.” (at 2)
Factual background
Pryor was a high‑school diver who was sexually abused by her coach in 2014. OSU allegedly knew of the abuse in August 2014 and fired the coach. Pryor filed a Title IX claim in January 2022, more than six years after turning eighteen.
Procedural history
The district court granted OSU’s summary‑judgment motion on the ground that the claim was barred by Ohio’s two‑year personal‑injury limitations period. Pryor appealed.