A Michigan Court Just Revived a Sexual Abuse Lawsuit the Trial Court Had Thrown Out. Here's the Legal Question That Turned It Around

Reviewed by Survivor Justice Alliance · Updated 2026-07-20

How the Case Was Dismissed the First Time

A Kent County Circuit Court judge dismissed the lawsuit in 2024 on statute of limitations grounds, reasoning that the applicable filing deadline had already run by the time the case was brought. The suit lists Grace Christian Reformed Church of Grand Rapids, along with the Christian Reformed Church in North America and several related entities, as defendants over allegations of childhood sexual abuse said to have occurred between 2006 and 2007.

At the time the abuse allegedly occurred, Michigan law gave a minor survivor until age 19 to file a civil claim. The lawsuit was not filed until 2024, well past that original deadline on its face, which is what led the circuit court to dismiss it.

The 2018 Reform, And Why Timing Mattered

In 2018, Michigan lawmakers extended the civil filing deadline for survivors who were minors at the time of their abuse, moving the cutoff from age 19 to age 28. The dispute on appeal was not whether that extension exists, but whether it could apply retroactively to someone whose original, shorter deadline had not yet expired when the reform passed.

The Court of Appeals sided with the survivor, reasoning that a claim which was still timely under the old rule when the 2018 reform took effect is exactly the kind of claim the legislature intended to protect and extend, not one that should be treated as already lost. The court distinguished that situation from a claim that had already expired before 2018, which the reform generally cannot revive on its own.

What the Ruling Means for Similar Cases

The decision matters beyond this one lawsuit because Michigan's 2018 reform affected an entire generation of survivors who were minors when it passed. Cases turning on the precise interaction between an old deadline and a new one are common in states that have extended limitations periods rather than eliminating them outright, and appellate guidance on how to apply that timing is often what determines whether a case proceeds or ends at the pleading stage.

The ruling sends the case back to Kent County Circuit Court to proceed, meaning the underlying factual allegations against the church and denominational entities have not yet been decided on the merits. A procedural win only restores the opportunity to litigate the claim; it does not establish that the abuse occurred as alleged.

The Institutional Response So Far

After the lawsuit was first filed, the Christian Reformed Church in North America issued a statement saying it takes abuse allegations seriously and pointing to existing child safety policies within the denomination, while the matter was reviewed. The denomination has not disputed that the underlying claim exists; the recent appellate fight was strictly about whether the case could proceed procedurally, not about the facts alleged.

The Alliance does not represent any party in this case and does not provide legal advice. Survivors in Michigan, or in any state that has changed its statute of limitations for abuse claims, should speak with a licensed attorney about how the timing of a specific law applies to their situation.

How Statute of Limitations Reforms Get Applied to Old Cases

This ruling turned on a timing question that comes up whenever a state extends its filing deadline. Here is how courts typically sort it out.

1. Was the claim already expired before the reform?: If the old deadline had already passed before a new law took effect, most states do not treat the new law as automatically reviving it.
2. Was the claim still timely when the reform passed?: Courts in this case found that a still-timely claim gets the benefit of the extended deadline, rather than being cut off early.
3. Who is named as a defendant matters: The suit named both the local church and the broader denominational body, reflecting how institutional liability claims often reach beyond a single local entity.
4. A dismissal on timing is not a ruling on the facts: The circuit court's original dismissal addressed only the filing deadline, not whether the alleged abuse occurred.
5. Appellate review can take years: The case was filed in 2024 and dismissed before an appeals court weighed in more than two years later, illustrating how long procedural fights alone can take.
6. A reversal sends the case back to trial court: The ruling does not decide the underlying claim; it allows the litigation to resume where it left off before dismissal.

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