Missouri court says man can sue St. Louis Archdiocese over abuse he repressed for decades

CNA Staff, Oct 16, 2025 / 11:48 am (CNA).

A Missouri appeals court has ordered that an alleged victim of clergy sexual abuse can sue the Archdiocese of St. Louis, ruling that an arcane aspect of bankruptcy law does not negate the archdiocese’s potential liability for abuse that the plaintiff allegedly repressed for decades.

The case touches on both the complex character of U.S. bankruptcy statutes as well as the often-protracted nature of abuse allegations, which frequently only come to light years or decades after the abuse is alleged to have occurred. 

In its Oct. 14 ruling, the Missouri Court of Appeals, Eastern District, said the alleged victim, John Doe, claims to have been abused at the St. Joseph’s Home for Boys in the late 1980s. 

Doe alleges that Father Alexander Anderson, who was assigned as a counselor to the home, sexually abused him; the plaintiff said he “reported the abuse [but] no action was taken,” according to the court. 

Doe “alleged he repressed his memory of the abuse until 2016,” the court said. He ultimately filed suit against the archdiocese in August 2022. 

The archdiocese argued in response that Doe’s abuse claim was effectively negated by two bankruptcy claims he had filed in 2008 and 2009. U.S. law dictates that when debtors file for bankruptcy, they create “an estate that includes nearly all of the debtor’s legal or equitable interests in property,” including legal causes of action. 

The archdiocese claimed that since Doe did not list his abuse claims as “exempted assets” in his bankruptcy proceedings, they became part of that “estate” and can only be administered by the trustee that handled those proceedings. 

The appeals court rejected the archdiocese’s argument, reversing a lower court decision and holding that Doe’s “cause of action” only arose when he said he remembered the alleged abuse in 2016, “well after” his bankruptcy filings. 

Doe’s standing to sue “did not accrue [when] the sexual abuse was allegedly committed” but rather when it was “capable of ascertainment,” the court held. 

The court’s ruling cited Missouri Supreme Court precedent, which holds that, in some cases of abuse, “the victim may be so young, mentally incompetent, or otherwise innocent and lacking in understanding that the person could not reasonably have understood that substantial harm could have resulted from the wrong.”

The St. Louis Archdiocese did not immediately respond to a request for comment on the ruling on Oct. 16. 

This is not the first instance in which the archdiocese has been held accountable for abuse allegations that an alleged victim claimed to have repressed for decades.

In 2023 the archdiocese agreed to pay a $1 million settlement to a man who said he was abused by Father Gary Wolken in the mid-1990s but repressed the memories until he was an adult. 

Wolken was in prison from 2003 to 2015 for sexually abusing another boy in the St. Louis area from 1997 to 2000. 

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