The Virginia Supreme Court has affirmed a lower court decision dismissing a civil lawsuit filed by an adult survivor of childhood sexual abuse based on statute of limitations grounds. In *Doe v. Green*, decided November 26, 2025, the court upheld the dismissal of claims against Joseph Robert Green Jr. over allegations arising from a sexual relationship that began in 2005.
Jane Doe filed her complaint on September 17, 2021, alleging claims of assault, battery, and intentional infliction of emotional distress against Green. She later amended her complaint to include claims of negligence per se, battery, and intentional infliction of emotional distress. The allegations center on a sexual relationship between Doe and Green that began in June 2005, when Doe was 14 years old and Green was 33.
According to the complaint, Green regularly emphasized the importance of keeping their sexual relationship secret. Doe alleged she was "constantly worried about getting in trouble, her lack of control over the relationship, and her parents' reaction, if the [sexual relationship] was discovered." The complaint further stated that Green would "occasionally pick up [Doe] from school and attend her soccer games from afar, contributing to her anxiety about the inappropriate nature of the [sexual relationship]."
The relationship ended in September 2006 when Doe ran away to New York. She returned to Virginia approximately two months later and claimed she became "increasingly angry at her parents for not protecting her from [Green]." The case took another turn in 2009 when Green reconnected with Doe via Facebook after she turned 18. Doe then contacted police and informed them about her previous sexual relationship with Green.
The Circuit Court of Fairfax County sustained Green's plea in bar based on the statute of limitations, effectively dismissing the case before trial. The Court of Appeals of Virginia affirmed that decision, prompting Doe's appeal to the Virginia Supreme Court.
The Virginia Supreme Court's opinion, written by Justice Cleo E. Powell, represents the final word on the matter. The court's decision to affirm the lower courts' rulings means that Doe's civil claims cannot proceed due to the passage of time between when the alleged conduct occurred and when she filed her lawsuit.
The case highlights the complex legal challenges facing adult survivors of childhood sexual abuse who seek civil remedies years or decades after the alleged conduct occurred. While the court record shows that Green was significantly older than Doe at the time of their relationship, the legal focus centered on procedural timing requirements rather than the merits of the underlying allegations.
The statute of limitations serves as a legal time limit within which civil lawsuits must be filed. These limitations are designed to ensure that cases are brought while evidence is fresh and witnesses are available, but they can create significant barriers for survivors of childhood sexual abuse who may not understand the nature of their experiences or feel able to come forward until they reach adulthood.
The 16-year gap between when the alleged relationship began in 2005 and when Doe filed her lawsuit in 2021 proved decisive in the case. The courts determined that too much time had elapsed for the civil claims to proceed under Virginia law.
The case record shows that Doe did contact police in 2009, two years after the statute of limitations for her civil claims may have expired. However, criminal proceedings and civil lawsuits are governed by different legal standards and time limits.
The Virginia Supreme Court's decision joins a body of case law addressing how statute of limitations laws apply to childhood sexual abuse cases. Different states have taken varying approaches to these time limits, with some extending or eliminating limitations periods for certain types of childhood sexual abuse cases.
The practical impact of the ruling is that Doe cannot pursue her civil claims for monetary damages against Green through the Virginia court system. The decision does not address or determine whether any criminal conduct occurred, as that would be a matter for separate criminal proceedings subject to different legal standards and procedures.
The case also illustrates the challenges courts face in balancing the need for timely legal proceedings against the reality that survivors of childhood sexual abuse may not be emotionally or psychologically prepared to pursue legal action until many years after the alleged conduct.
While the specific details of what transpired between Doe and Green remain unresolved due to the procedural dismissal, the case underscores ongoing policy debates about how legal systems should address claims by adult survivors of childhood sexual abuse when significant time has elapsed since the alleged conduct occurred.