DeCrescenzo v. Church of Scientology
Laura Ann DeCrescenzo appeals a judgment dismissing her complaint against Church of Scientology International (Scientology) and Religious Technology Center (collectively, defendants) after the sustaining of demurrers without leave to amend based on the statutes of limitations. Plaintiff contends she has adequately pled a combination of delayed discovery of her causes of action and a basis for equitable estoppel precluding defendants from asserting a statute of limitations defense. Our review of this record compels the conclusion that plaintiff has adequately alleged that (1) she was unable to comprehend the wrongfulness of the defendants' conduct for a period of time and that her causes of action did not accrue until she did so and (2) even after her delayed discovery of her causes of action, the defendants' threats and intimidation caused her to delay filing her complaint. In addition, we reject defendants' contention that plaintiff is collaterally estopped from prosecuting her action by a federal court judgment that equitable estoppel was inapplicable because the facts alleged in plaintiff's prior complaint were insufficient to demonstrate reasonable reliance on defendants' representations. We hold that her allegations of additional facts in the present complaint establish a basis for reasonable reliance and such new allegations are not precluded by the federal judgment. We therefore will reverse the judgment with directions.
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