Independent New Hampshire Journalism · Northfield, NHCorrection and update, Sept. 19, 2026, 3:14 p.m. EDT: An earlier version of this article said the Diocese of Manchester “welcomed the ruling as necessary to defend against very old claims,” and it labeled links to the New Hampshire General Court’s statute website as the “New Hampshire Gaming Control Board.” In fact, the Associated Press reported that the diocese said in a statement that defending such lawsuits can be difficult, if not impossible, because witnesses and evidence may no longer be available, and the statute links go to the General Court (AP; N.H. General Court). We corrected both, added the 3-0 vote, the opinion citation and a link to the opinion, and added that as of September 2026 the General Court’s posted text of RSA 508:4-g lists no amendment after 2020.
NH Supreme Court Says 2020 Repeal of Civil Statute of Limitations for Sexual Assault Can’t Be Applied Retroactively
By Granite State Report
CONCORD — Oct. 15, 2025. New Hampshire’s highest court ruled that the state’s 2020 elimination of the civil statute of limitations for sexual assault (RSA 508:4-g) cannot be used to revive claims that were already time-barred before the law took effect on September 18, 2020. The 3-0 decision, written by Justice Patrick Donovan in Randy Ball v. Roman Catholic Bishop of Manchester, 2025 N.H. 45 (No. 2024-0606), leaves in place a lower-court dismissal of a lawsuit alleging 1970s abuse at a Catholic summer camp. The justices said retroactive application would violate the state constitution’s ban on retrospective laws and the vested right to a limitations defense. (Opinion; AP News)
What the court decided
The court held that, although RSA 508:4-g now says survivors “may commence a personal action at any time,” that 2020 change cannot revive claims whose deadlines had already expired under earlier law. The opinion rests on Part I, Article 23 of the N.H. Constitution, which says “[r]etrospective laws are highly injurious, oppressive, and unjust” and that no such laws “should be made, either for the decision of civil causes, or the punishment of offenses.” The court held that once a limitations period has run, a defendant’s right to rely on that defense is vested and cannot be taken away by later legislation. The justices assumed, without deciding, that lawmakers meant the 2020 change to apply retroactively. (Ball opinion; RSA 508:4-g, N.H. General Court)
The case behind the ruling
Plaintiff Randy Ball sued the Diocese in 2023, alleging he was raped by a priest at Camp Fatima in the mid-1970s. Under the law then in force, he had until age 20 (1986) to file; the 2020 amendment removed deadlines for civil sexual-assault claims, but the Supreme Court said that change can’t reach back to revive claims already expired decades ago. Briefs and docket materials for Ball are posted by the Judicial Branch. (InDepthNH.org)
What the ruling means
Practically, survivors whose civil claims expired before Sept. 18, 2020, likely remain barred from suing based solely on the 2020 law. Survivors with claims that had not yet expired as of that date may still benefit from RSA 508:4-g’s removal of deadlines going forward. In a statement provided by its attorneys, the Diocese of Manchester said defending such lawsuits can be difficult, if not impossible, because witnesses and evidence may no longer be available. The court wrote that it is “acutely aware that victims of child sex abuse are some of the most vulnerable victims,” acknowledged that the result “may prevent some victims who have been impacted by sex abuse” from bringing expired claims, and said its role is to interpret the constitution. (AP News)
How New Hampshire compares
Maine’s Supreme Judicial Court reached a similar result on January 28, 2025, ruling 5-2 that retroactive application of that state’s 2021 law reviving time-barred civil child-sex-abuse claims was unconstitutional (Dupuis v. Roman Catholic Bishop of Portland, 2025 ME 6). The regional trend suggests that “look-back” windows or retroactive revivals face steep constitutional headwinds in some New England courts. (Maine Courts)
Primary sources & further reading
- AP recap of the ruling (Oct. 15, 2025): New Hampshire’s 2020 law can’t be applied retroactively. (AP News)
- Statute text (RSA 508:4-g): Current law stating survivors “may commence a personal action at any time.” (N.H. General Court)
- Opinion (Oct. 15, 2025): Ball v. Roman Catholic Bishop of Manchester, 2025 N.H. 45. (Opinion PDF, CourtListener)
- Case page & filings: Randy Ball v. Roman Catholic Bishop of Manchester docket and briefs. (New Hampshire Judicial Branch)
- Context features on the Camp Fatima litigation: Reporting leading up to oral arguments. (InDepthNH.org)
- Comparative development in Maine: Official opinion PDF and coverage. (Maine Courts)
Related video reporting (YouTube)
- WMUR segment: “Statute of limitations argued in sexual abuse lawsuit against Diocese of Manchester” — background on the Camp Fatima case (June 4, 2024). https://www.youtube.com/watch?v=v09s1MV5eiU
If you need help
New Hampshire’s 24/7 confidential hotline connects survivors to local crisis centers for free support, advocacy, and services: 1-866-644-3574. More resources are available via the N.H. Coalition Against Domestic and Sexual Violence. (nhcadsv.org)
What to watch: How lower courts apply this ruling to similar cases, and whether lawmakers pursue options that could pass constitutional muster without reviving expired claims. As of September 2026, the General Court’s posted text of RSA 508:4-g lists no amendment after 2020. (N.H. General Court)
Corrections: Granite State Report corrects verified errors promptly and appends a dated note identifying what changed and when. The corrections policy and the corrections register are public, and correction notes are never removed.
