S.K., et al. v. State of Oregon, et al.

Summary

The United States District Court for the District of Oregon denied Defendants’ Rule 12(b)(6) motion to dismiss Plaintiff E.G.’s claims under 42 U.S.C. § 1983. The court held that the claims were not plainly time-barred because the complaint plausibly alleged delayed discovery of the constitutional injuries and their cause. The court also held that the allegations plausibly stated supervisory-liability claims against the individual defendants for allegedly failing to respond to known sexual abuse in Oregon Youth Authority custody.

Holdings

1. The claims were not subject to dismissal as time-barred because the running of the statute of limitations was not apparent on the face of the complaint, and the allegations plausibly supported delayed discovery of the constitutional injuries and their cause.
2. E.G. plausibly alleged that the individual defendants were liable in their individual capacities for their own supervisory conduct because they knew or reasonably should have known of the physician's abuse and failed to take reasonable steps to stop it or protect youth in OYA custody.

Questions Presented

1. Whether E.G.'s § 1983 claims were barred by the applicable statute of limitations at the pleading stage.
2. Whether E.G. plausibly alleged that the individual OYA defendants were liable under § 1983 for their own supervisory conduct, including knowingly failing to stop or prevent the alleged abuse.

Disposition

other