California Court of Appeal, First Appellate District, Division Two (opinion by Justice Miller) · California Court of Appeal · Court deciding Jane Doe #21 (S.H.) v. CFR Enterprises, Inc.
Finding: Under the 2022 version of section 340.16(e), a plaintiff must allege a cover up by the liable entity that predated her assault, but the cover up need not involve a prior assault by the same individual; a cover up of earlier assault or allegations by an alleged perpetrator can suffice.
Jane Doe #21 (S.H.) v. CFR Enterprises, Inc. (2023) 93 Cal.App.5th 1199, Cal. Ct. App., First Dist., Div. Two, No. A163543 (filed June 29, 2023; certified for publication July 27, 2023) (opens in a new tab) · Jun 29, 2023 · Checked Oct 5, 2026
