Balancing the Statute of Limitations and the Discovery Rule: Victims of Incestuous Abuse Are Denied Access to Washington Courts—Tyson v. Tyson

Authors

Naomi Berkowitz

Abstract

This Note addresses the Washington Supreme Court’s reasoning in Tyson v. Tyson in light of the incest victim and the nature of her injury, with a focus on the justification for the statute of limitations and the development of the discovery rule exception in Washington law. This Note then argues for the logical and just extension of the discovery rule to cases involving the victims of repeated incestuous abuse who discover the abuse after the statute of limitations has run.

Recommended Citation

Naomi Berkowitz, Balancing the Statute of Limitations and the Discovery Rule: Victims of Incestuous Abuse Are Denied Access to Washington Courts—Tyson v. Tyson, 10 SEATTLE U. L. REV. 721 (1987).