Norman Redwing v. Catholic Bishop for the Diocese of Memphis

Lower Court summary
Plaintiff filed an action against the Catholic Bishop for The Diocese of Memphis, asserting the Diocese was liable for damages arising from the negligent hiring, retention and supervision of a priest, who Plaintiff alleged abused him when he was a child. The Diocese moved to dismiss for lack of subject matter jurisdiction and on the grounds that the statute of limitations prescribed by Tennessee Code Annotated § 28-3-104 had expired. The trial court denied the motions. It also denied the Diocese’s motion for permission to seek an interlocutory appeal pursuant to Rule 9 of the Tennessee Rules of Appellate Procedure. We granted the Diocese’s motion for extraordinary appeal under Rule 10. We affirm the trial court’s judgment with respect to subject matter jurisdiction over Plaintiff’s claim of negligent supervision, but hold that Plaintiff’s claims of negligent hiring and negligent retention are barred by the ecclesiastical abstention doctrine. We reverse the trial court’s judgment with respect to the expiration of the statute of limitations.