The U.S. Court of Appeals for the Second Circuit issued a summary order Jan. 29 in *Doe 2 v. Congregation of the Sacred Hearts et al.*, a case involving sexual abuse allegations against multiple Catholic religious organizations.
The case, designated as No. 24-2940, involves two anonymous plaintiffs identified as Jane Doe 2 and Jane Doe 1 who are appealing against four Catholic institutions: The Congregation of the Sacred Hearts of Jesus and Mary, the Roman Catholic Diocese of Fall River, Sisters of Charity of Montreal, and Sisters of Charity of Quebec.
A three-judge panel heard the case at the Thurgood Marshall United States Courthouse in New York City. The panel consisted of Chief Judge Debra Ann Livingston and Circuit Judges William J. Nardini and Alison J. Nathan.
The court document indicates that additional defendants were also named in the case, including "Black and White Corporations 1-10" and the Missionary Oblates of Mary Immaculate Eastern Province, though these entities are listed as defendants rather than defendants-appellees.
According to court records, the plaintiffs are represented by Rob Rickner of Rickner PLLC in New York. The defendants-appellees are represented by Sanford N. Talkin of Talkin, Muccigrosso & Roberts LLP, also based in New York, specifically for The Congregation of the Sacred Hearts of Jesus and Mary.
The summary order format indicates this ruling does not establish binding precedent. Federal appellate courts use summary orders for cases that do not require detailed written opinions, typically when the legal issues are straightforward or when the court's reasoning follows established precedent.
Under Federal Rule of Appellate Procedure 32.1 and the Second Circuit's Local Rule 32.1.1, summary orders filed after Jan. 1, 2007, may be cited in legal documents. However, parties citing such orders must reference either the Federal Appendix or an electronic database and must include the notation "summary order." Additionally, any party citing a summary order must serve a copy on parties not represented by counsel.
The Second Circuit's handling of this case reflects the federal court system's ongoing management of clergy abuse litigation. Such cases often involve complex jurisdictional issues, statute of limitations questions, and claims against multiple institutional defendants.
The involvement of multiple Catholic organizations as defendants suggests the scope of the alleged abuse may have crossed institutional boundaries. The Congregation of the Sacred Hearts of Jesus and Mary is a Catholic religious congregation, while the Roman Catholic Diocese of Fall River oversees Catholic parishes and institutions in southeastern Massachusetts. The Sisters of Charity organizations named as defendants operate in different regions, with Montreal and Quebec connections indicating potential cross-border institutional relationships.
The use of "Jane Doe" pseudonyms is standard practice in sexual abuse litigation, protecting the identities of alleged victims while allowing cases to proceed through the court system. This anonymity provision recognizes the sensitive nature of such allegations and the potential for additional harm to plaintiffs if their identities were disclosed.
The case's progression to the Second Circuit indicates that a lower court previously ruled on the matter, and the plaintiffs are seeking to challenge that decision. The Second Circuit Court of Appeals has jurisdiction over federal cases from New York, Connecticut, and Vermont.
While the specific details of the lower court's decision and the grounds for appeal are not detailed in the available summary order header, the case represents part of broader litigation patterns involving institutional liability for clergy abuse. Such cases often involve questions of institutional knowledge, supervisory responsibility, and the extent to which religious organizations can be held liable for the actions of their members.
The timing of this case, with arguments heard in late January 2026, places it within an ongoing wave of clergy abuse litigation that has continued across multiple decades. Many such cases have been facilitated by changes in state statute of limitations laws, which have opened new avenues for survivors to seek legal remedies.
The court documents indicate that amendments to the case caption were requested, suggesting ongoing procedural adjustments as the litigation progresses. Such modifications are common in complex institutional litigation involving multiple defendants and evolving legal strategies.
The outcome of this summary order, while not yet disclosed in the available documents, will determine whether the plaintiffs' appeals succeed and what remedies, if any, may be available. The case adds to the substantial body of federal appellate case law addressing institutional liability in clergy abuse cases.