Description
URL: https://floodlit.org/cmp-241202-cacd/
Description: Civil complaint
Case title: Jane Roe CP 76 v. Doe 1 et al
Case number: 5:24-cv-02583
Court: California Central District
Date filed: 2024-12-02
Pages: 25
Changes made by FLOODLIT.org: None
The plaintiff, Jane Roe CP 76, an adult woman over 40 using a pseudonym to protect her privacy, alleges childhood sexual abuse by a Mormon religious figure, Brother Ross, between 1978 and 1980 when she was 9 to 10 years old. The defendants include religious entities identified as DOE 1, DOE 2, DOE 3, and DOES 4 through 100, accused of negligence and other failures related to the abuse.
Defendants:
DOE 1: A Utah-based corporation operating wards, meetinghouses, congregations, and temples in California, with its principal place of business at 50 East North Temple, Salt Lake City, UT.
DOE 2: A subsidiary of DOE 1, also a Utah corporation, managing properties and temples in California.
DOE 3: A California corporation sole operating congregations and wards in San Bernardino County under DOE 1’s direction, located at 12776 6th Street, Yucaipa, CA.
DOES 4-100: Unnamed individuals or entities whose identities are yet to be determined.
Alleged perpetrator: Brother Ross, identified as a “High Priest” and “Member of the Quorum of the Seventy” (possibly a stake seventy) within DOE 1.
Background
Jane Roe CP 76 was a minor member of the defendants’ church in Yucaipa, California, during the late 1970s. She alleges that Brother Ross, a high-ranking church official, used his authority to groom and sexually abuse her over two years. The abuse included grooming, manipulation, fondling, oral sex, and vaginal penetration, occurring at various locations, including the church meetinghouse. The plaintiff claims the defendants—religious organizations tied to the Church of Jesus Christ of Latter-day Saints (implied but not explicitly named in the summary)—knew or should have known about Ross’s predatory behavior but failed to protect her or report the abuse.
Allegations
The plaintiff alleges that:
– Brother Ross exploited his position to isolate and abuse the plaintiff, including taking her to the church (where he had keys) and forcing sexual acts after Sunday services, culminating in rape. He allegedly threatened her life to ensure her silence.
– The defendants maintained detailed membership records, including annotations for serious offenses like sexual abuse, yet failed to act on Ross’s behavior despite having mechanisms to track such conduct.
– The defendants engaged in a pattern of concealing abuse to protect the church’s reputation and finances, including a helpline staffed by attorneys from Kirton McConkie who advised bishops not to report abuse to authorities, citing clergy-penitent privilege.
Causes of Action
The plaintiff asserts six causes of action against all defendants:
Negligence: Defendants breached their duty of care by failing to protect the plaintiff from Ross’s known or suspected abuse.
Negligent Supervision of a Minor: Defendants failed to supervise and protect the plaintiff, allowing unsupervised access to Ross.
Sexual Abuse of a Minor: Ross committed unlawful sexual acts, and defendants ratified his conduct by not intervening despite awareness of his behavior.
Negligent Hiring, Supervision, and Retention: Defendants failed to investigate, hire, train, or supervise Ross adequately, enabling his abuse.
Negligent Failure to Warn, Train, or Educate: Defendants did not warn the plaintiff or others about Ross or educate them on identifying and reporting abuse.
Breach of Mandatory Duty: As mandated reporters under California’s Child Abuse and Neglect Reporting Act (Penal Code § 11166), defendants failed to report suspected abuse to authorities.
Relief Sought
Jane Roe CP 76 seeks:
– Damages: Compensation for physical and mental pain, emotional distress, psychological harm, medical costs, and lost earnings (past and future), with amounts exceeding the court’s minimum jurisdictional limits.
– Additional Relief: Attorney’s fees, costs of suit, and any other relief deemed just by the court.
– Jury Trial: The plaintiff demands a trial by jury.
The case was filed under Code of Civil Procedure § 340.1, which addresses the statute of limitations for childhood sexual abuse claims. A tolling agreement with DOE 1 extended the filing deadline to August 26, 2024.
This document appears under a federal case number (5:24-cv-02583-SSS-SP), filed on Dec. 2, 2024.
There is also a state court filing (CIVSB2426280) from Aug. 26, 2024, filed in the Superior Court of California, San Bernardino County.
FLOODLIT.org, a nonprofit, compiled and published this document in Feb. 2025 as part of its mission to report on alleged sex crimes by members of the Church of Jesus Christ of Latter-day Saints (Mormon/LDS church) and organizational misconduct related to sexual abuse. FLOODLIT relies on public donations to fund its investigative reporting and case documentation efforts.
