Long-buried claim of rapist priest at Catholic summer camp puts N.H.'s statute of limitations to the test

Boston Globe

17-06-2025

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According to the plaintiff, counselors at the camp would play a game they called 'strip the campers,' in which adults would chase children and remove clothing from whoever they caught.
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In his efforts to avoid being forcibly disrobed, the plaintiff recalled hiding behind a bench where three adults laughed at him, and one directed him to hide in a nearby cabin. The camp's director,
The plaintiff alleges Dowd told him to rest on a bed, where he could watch the other campers through the window. Then Dowd climbed onto the bed and raped the child, while saying that he and God both loved the boy and wanted him to be there, according to the lawsuit.
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This wasn't the first allegation of predatory behavior at Camp Fatima, nor was it the first against Dowd. Several other claims
More than 20 years later, states are still struggling with how to hold abusers accountable — and whether statutes of limitations apply. As society's understanding of trauma and its complex impacts on victims has evolved, many states have sought to give survivors more time to file litigation seeking accountability from individuals and institutions, especially in cases of childhood sexual abuse.
Heed's report concluded the diocese could be criminally charged with endangering the welfare of minors for failing to protect children from priests who had abused kids in the past. In lieu of prosecution, the attorney general's office reached an agreement with the diocese and released the facts that investigators had uncovered.
Dowd's name appears among dozens of others on the diocese's
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New Hampshire lawmakers enlarged the statute of limitations repeatedly in the 2000s, then abolished it altogether in 2020; however, the 2023 lawsuit over Dowd's alleged conduct at Camp Fatima is now testing whether the abolishment of the statute of limitations applies retroactively.
The diocese contends the plaintiff could have filed his lawsuit until 1986, when he turned 20 years old, since the statute of limitations that was in effect at the time gave childhood victims until two years after they attained adulthood to bring such claims. The diocese contends the expiration of the prior statute of limitations created a 'vested right' that state lawmakers cannot revoke later on — and Superior Court Judge Elizabeth M. Leonard agreed.
'The Court acknowledges that the plaintiff is one of many who was not served by the prior law,' Leonard wrote in a decision last fall granting the diocese's motion to dismiss this case. 'However, the fact that the current law allows the plaintiff a path of recovery cannot justify the revival of a time-barred claim through the retrospective application of the law.'
'Ultimately, it would be more unjust to allow for a system in which vested rights can be taken away by subsequent legislative amendments,' Leonard added.
The plaintiff's attorneys, Scott H. Harris and Stephen A. Weiss, have appealed to the New Hampshire Supreme Court, urging the justices to overrule Leonard's decision and prioritize their client's right to seek a judicial remedy over the diocese's right to be free from previously time-barred litigation.
Harris and Weiss argued the concept of an unambiguous vested right is 'especially odd' in a case like this one, since a hypothetical plaintiff in similar circumstances might be granted more time to bring allegations of decades-old misconduct if they didn't know enough earlier on about the existence of their potential claim.
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'Statutes of limitations are important tools to encourage parties to bring their disputes to court promptly, while memories are still fresh and evidence still available,' they wrote in a court filing. 'Statutes of limitation are not, however, substantive law that determines the merits of a disputed claim.'
Harris and Weiss argue the diocese was negligent. They say church leaders either knew or should have known children were being sexually abused at Camp Fatima. And they fault the diocese for naming Dowd as camp director in 1971 shortly after he was accused of fondling a teenage boy in Keene, N.H.
During oral arguments, an attorney for the diocese, Olivia F. Bensinger, will argue that Leonard's decision was correct. In a statement, Bensinger framed the outcome as a matter of practical fairness.
'As the statute of limitations law recognizes, a lawsuit concerning a report of abuse that is many years old can be difficult, if not impossible, to defend because witnesses and evidence may no longer remain available,' she said.
Bensinger said the diocese has been working for more than two decades to meet the needs of victims and survivors of abuse, and the diocese has implemented safeguards to foster safe environments at parishes, schools, and camps to protect kids.
While this case in New Hampshire echoes similar disputes across the country, state courts have
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In Maine, the Supreme Judicial Court
The New Hampshire Supreme Court may be inclined to reach a similar conclusion, especially since the state's constitution expressly prohibits retrospective laws as '
New Hampshire's constitution is one of only seven nationwide — and the only one in New England — with such a clear-cut prohibition.
Steven Porter can be reached at