A Michigan Court Just Revived a 'Too Late' Abuse Claim. Here's What That Means If Yours Was Dismissed

Reviewed by Abuse Justice Center · Updated 2026-07-19

A Claim the Trial Court Said Came Too Late

A survivor sued a Grand Rapids congregation and its larger national denomination in 2024, by then 21 years old, alleging she had been sexually abused inside the church starting when she was three. A Kent County judge dismissed the case, ruling that whatever filing deadline applied to her had already passed by the time she brought the claim.

That kind of dismissal is exactly what survivors fear when they finally come forward years later. It also turned out, according to the appeals court, to be wrong. Michigan lawmakers changed the relevant deadline for cases like hers back in 2018, and the trial court had not applied that change correctly.

The 2018 Law the Trial Court Missed

In 2018, Michigan extended the window for survivors who were minors at the time of their abuse, letting them file a civil claim up until they turn 28 rather than cutting them off at 19 as older law required. Lawmakers built that extension around a well-documented reality: children abused very young often do not process or disclose what happened to them until well into adulthood, if ever, on the timeline the old deadline assumed.

The appeals court's ruling this week held that this 2018 extension covers survivors like the plaintiff here, whose abuse predated the amendment but who had not yet turned 19, the old cutoff, when the law changed. That combination, abuse that happened before 2018 but a survivor who was still young enough for the new deadline to apply, is exactly the kind of case the reform was written for.

Why an Appeals Ruling Matters Beyond One Case

A single appellate decision does not rewrite Michigan law. What it does is settle, at least for now, how a specific and recurring fact pattern gets treated: abuse that occurred years before 2018, brought by someone who was a minor when the amendment passed. Trial courts across the state handle these calculations differently, and a published appellate ruling gives them, and the attorneys arguing before them, a clearer answer.

For survivors, the practical lesson is narrower and more useful: a dismissal on statute-of-limitations grounds is not always the final word, especially in states that have amended their deadlines in the last decade. Michigan is one of many states that has adjusted how long survivors have to sue an institution, and the math around exactly which deadline applies to which birth year and abuse date gets complicated fast.

• Abuse alleged to have occurred in this case: 2006 to 2007, when the survivor was three to four years old
• Old Michigan deadline for minors at the time of abuse: file by age 19
• New deadline created by the 2018 amendment: file by age 28
• Lawsuit originally filed: 2024, when the survivor was 21
• Trial court result: dismissed as untimely
• Appeals court result, ruled this week: dismissal reversed, case may proceed

If You Were Told Your Claim Was Too Late

If an institution's attorney, or even a lawyer you consulted, told you your childhood abuse claim in Michigan was time-barred, this ruling is a reason to ask the question again, especially if you were a minor when the abuse happened and were still under 19 in 2018. The same is true in other states that have passed similar extensions or opened lookback windows in recent years: an earlier no is not always the last word once the law has changed underneath it.

This is exactly the kind of fact-specific calculation an attorney who handles institutional abuse cases should walk through with you, free of charge, before you accept that a door is closed. Nothing about a prior dismissal, or the passage of time since the abuse happened, means you should assume you have no options left.

What to Check If a Michigan Abuse Claim Was Dismissed as Too Late

Statute-of-limitations dismissals often turn on details survivors were never told mattered. These are the questions worth asking before accepting that a claim is closed.

1. How old were you when the abuse happened: Michigan's 2018 extension applies specifically to people who were minors at the time they were abused, not adult survivors of adult assault.
2. How old were you in 2018: The extension mattered most for survivors who had not yet aged out under the old 19-year cutoff when the new law took effect.
3. Which entity is named: This case named both a local congregation and its larger national denomination, since institutional claims often reach further up the organizational chain than survivors realize.
4. When did you connect the harm to the abuse: Courts increasingly recognize that survivors abused very young may not process the connection between their injuries and the abuse until much later.
5. Was the dismissal based on the old deadline: A previous dismissal calculated under the pre-2018 rule may not reflect how a court would rule today.
6. Has your state changed its own deadline recently: Michigan is one of many states that has extended filing deadlines or opened temporary lookback windows in the last several years.

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