GATEWAY’S PEDOPHILE PASTOR ROBERT MORRIS’ SEX ABUSE ALLEGATIONS SHOULD REVIVE “REVIVAL LAWS” IN TEXAS THAT GIVE CHILD VICTIMS A PERIOD OF TIME TO FILE CIVIL SUITS IN CASES WHERE THEIR ABUSE COMES TO LIGHT AFTER THE STATUTE OF LIMITATIONS HAS EXPIRED.
DANIEL WHYTE III, PRESIDENT OF GOSPEL SOCIETY INTERNATIONAL, SAYS ROBERT MORRIS AND THE GATEWAY CHURCH ORGANIZATION SHOULD NOT PUT THIS WOMAN THROUGH ANY MORE HELL AND OUGHT TO OFFER HER POST HASTE A LOVE OFFERING OF $3 MILLION FOR THE HELL SHE HAS ENDURED AND $1 MILLION TO HER PARENTS (IF THEY ARE STILL LIVING) FOR THE PAIN AND HURT OF HER PARENTS WHO WERE TRYING TO HELP HIM IN THE MINISTRY AS A YOUNG PREACHER.
That’s important because sexual abuse silences young victims, often for decades and sometimes even for a lifetime.
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Revival Laws for Child Sex Abuse
30 U.S. States & Territories Revived Previously Expired Child Sex Abuse Claims with a Window and/or Age Limit Revival Law
Alice Nasar Hanan, Esq.
Updated June 6, 2024
CHILD USA and CHILD USAdvocacy are leading the vibrant national and global movement to eliminate civil and criminal SOLs and revive expired civil claims as a systemic solution to the preventable CSA epidemic.
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I. What Are Revival Laws and Why Do We Need Them?
It is a medical fact that victims of child sex abuse often need decades to come forward. They are traumatized from the abuse, incapable of processing what happened to them, and often dependent on the adults who perpetrated or caused the abuse. In a study of survivors of abuse in Boy Scouts of America, 51% of survivors disclosed their abuse for the first time at age 50 or older. One-third of CSA survivors never tell anyone they were abused. By the time many victims are ready to come forward, the courthouse doors are locked because the statutes of limitations (SOL) for claims expired. Revival laws honor and empower the victims of child sex abuse who faced locked courthouse doors due to unfairly short SOLs.
There is only one way to restore justice to adult victims of child sex abuse whose civil and criminal SOLs have expired, and that is to revive their civil claims. This is because the U.S. Constitution prohibits revival of criminal prosecutions, but allows revival of civil causes of action. Revival laws are not solely about justice for victims; there are also important public safety reasons for allowing older claims of abuse to proceed. When victims are empowered to disclose their abuse and sue for their injuries, the public benefits in many ways. Revival laws serve three compelling purposes: (1) they help identify hidden child predators and institutions that endanger children to the public shielding other children from future abuse; (2) they shift the cost of the abuse from the victims and taxpayers to those who caused it; and (3) they educate the public about the prevalence, signs, and impact of child sex abuse so that it can be prevented in the future.
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II. State-by-State Overview of All Revival Laws Since 2002
A timeline of all CSA revival laws enacted since 2002 is provided in the graphic below.
A full list of the CSA revival laws in 33 U.S. States and Territories (30 States + 3 Territories) is provided
in the following chart.*
State Revival Law
Type
Window
Dates
Age
Limit
Revival Law Description
Alabama 1+ Year Window
(2024)
Open
4/3/24-
1/31/26
1-year and 10-month window for expired
claims against the Boy Scouts of America
bankruptcy estate opened on April 3, 2024.1
Arizona 1.5-Year
Window
& Age 30 Limit
(2019)
Closed
5/27/19-
12/30/20
Age
30
Permanently revived claims up to age 30 and
1.5-year window for expired claims against all
types of defendants closed on December 30,
2020.2
Arkansas 2-Year Window
(2023)
Open
2/1/24-
1/31/26
2-year window for expired claims against all
types of defendants opened on February 1,
2024, and closes on January 31, 2026.3
1.5-Year
Window (2021)
Closed
2/1/22-
7/31/23
1.5-year window for expired claims against all
types of defendants opened on February 1,
2022, and closed on July 31, 2023.4 The
window was set to be open for 2 years, but the
later window statute shortened it, creating a 6-
month gap period between windows.
* This list does not include revival via delayed discovery rule or criminal conviction revival provisions.
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4
California 3-Year Window
& Age 40 Limit
(2019)
Closed
1/1/20-
12/31/22
Age
40
Permanently revived claims up to age 40 and 3-
year window for expired claims against all
types of defendants closed on December 31,
2022.5
1-Year Window
(2004)
Closed
1/1/05-
12/31/05
1-year window for expired claims against
perpetrators who were being criminally
prosecuted under California Penal Code §
803(g)’s criminal SOL revival provision, but
whose criminal case was overturned as a result
of U.S. Supreme Court ruling in Stogner.
6
1-Year Window
(2003)
Closed
1/1/03-
12/31/03
1-year window for expired claims against
private organizations and non-perpetrator
individuals only closed on December 31, 2003.7
Colorado* 3-Year Window
(2021)
Closed
1/1/22-
12/31/24
3-year window for claims against perpetrators,
private organizations, and government for
abuse from 1960-2021 opened on January 1,
2022. In 2023, the window was held
unconstitutional.8 *The law is not a revival
law—it is a new cause of action—but it is
included because it opened a window to justice
for many survivors whose common law claims
were expired.9
Connecticut Age 48 Limit
(2002)
Age
48
Permanently revived claims up to age 48
against all types of defendants.10
Delaware 2-Year Window
(2010)
Closed
7/13/10-
7/12/12
2-year window for expired claims against
healthcare providers was added in 2010
because original window did not apply to
them.11
2-Year Window
(2007)
Closed
7/10/07-
7/9/09
2-year window for expired claims against all
types of defendants closed on July 9, 2009.12
Georgia 2-Year Window
(2015)
Closed
7/1/15-
6/30/17
2-year window for expired claims against
perpetrators only closed on June 30, 2017.13
Guam Permanent
Window
(2016)
Open
9/23/16-
never
closes
No
age
limit
Permanently open revival window for all
expired claims against all types of defendants
opened on September 23, 2016.14
2-Year Window
(2011)
Closed
3/9/11-
3/8/13
2-year window for expired claims against
abusers only closed on March 8, 2013.15
Hawaii 2-Year Window
(2018)
Closed
4/24/18-
4/23/20
2-year window for expired claims against all
types of defendants closed on April 23, 2020.16
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5
2-Year Window
(2014)
Closed
4/24/14-
4/23/16
In 2014 original window was extended for
another 2 years and expanded to include claims
against the government.17
2-Year Window
(2012)
Closed
4/24/12-
4/23/14
2-year window for expired claims against
perpetrators, other individuals, and private
organizations closed on April 24, 2014.18
Indiana 1+ Year Window
(2024)
Open
3/12/24-
7/1/25
1-year and 3-month window for expired claims
against the Boy Scouts of America bankruptcy
estate opened on March 12, 2024.19
Iowa 1+ Year Window
(2024)
Open
4/19/24-
12/31/26
1-year and 9-month window for expired claims
against the Boy Scouts of America bankruptcy
estate opened on April 19, 2024.
20
Kansas Age 31 Limit Age
31
Revives SOL up to age 31 or 3 years after
criminal conviction.21
Kentucky Limited Window
(2021)
Closed
5 years
after SOL
expired
Limited window reviving expired claims for up
to 5 years after the date the SOL previously
expired opened on March 23, 2021.22 The
revival was held unconstitutional.23
Louisiana 2+ Year Window Opening
soon
8/14/24-
6/13/27
Nearly 3-year window extension will open on
August 1, 2024.
24
3-Year Window
(2021)
Open
6/14/21 –
6/13/24
3-year window for expired claims against all
types of defendants opened on June 14, 2021.25
Maine Permanent
Window
(2021)
Open
10/28/21-
never
closes
No
age
limit
Permanently open revival window for all
expired claims against all types of defendants
opened on October 18, 2021. Sovereign
immunity laws still block window claims
against the state.26
Maryland Permanent
Window
(2023)
Open
10/1/23-
never
closes
No
age
limit
Permanently open revival window for all
expired claims against all types of defendants
opened on October 1, 2023.27
Mass. Age 53 Limit
(2014)
Age
53
Permanently revived claims up to age 53
against perpetrators only.28
Michigan 90-Day Window
(2018)
Closed
6/12/18 –
9/10/18
90-day window reviving claims for victims of
Larry Nassar only closed on September 10,
2018.29
Minnesota 3-Year Window
(2013)
Closed
5/26/13-
5/25/16
3-year window for expired claims against all
types of defendants closed on May 25, 2016.30
Montana 1-Year Window
& Age 27 Limit
(2019)
Closed
5/7/19 –
5/6/20
Age
27
Permanently revived claims up to age 27 and 1-
year window for expired claims against
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perpetrators and entities closed on May 6,
2020.31
Nevada Permanent
Window & Age
38 Limit
(2021)
Open
6/2/21-
never
closes
Age
38
Permanently open revival window for all
expired claims against perpetrators or persons
criminally liable for sexual abuse or
exploitation of a minor (including trafficking,
prostitution, and pornography) and promoters,
possessors, or viewers of CSAM (child sexual
abuse material) opened on June 2, 2021. Also,
permanently revives claims up to age 38 for
CSA and sexual exploitation of a minor against
other defendants.32
New Jersey 2-Year Window
& Age 55 Limit
(2019)
Closed
12/1/19 –
11/30/21
Age
55
Permanently revived claims up to age 55 and 2-
year window for expired claims against all
types of defendants closed on November 30,
2021. Window applies to child sex abuse
victims and those sexually assaulted as adults.33
New York 2-Year Window
(2022)
Open
3/1/23-
3/1/25
2-Year window for expired gender-motivated
violence, including CSA and sexual assault
claims, will open on March 1, 2023, against all
types of defendants for abuse that occurred in
New York City—Manhattan, Queens, Staten
Island, Brooklyn, and the Bronx.34
1-Year Window
(2020)
Closed
8/14/20-
8/13/21
In 2020 extended original window by one year
which closed on August 13, 2021.35
1-Year Window
(2019)
Closed
8/14/19-
8/13/20
1-year window for expired clams against all
types of defendants opened on August 14,
2019.36
North
Carolina
2-Year Window
(2019)
Closed
1/1/20 –
12/31/21
2-year window for expired civil claims against
all types of defendants closed on December 31,
2021.37
Northern
Mariana
Islands
Permanent
Window
(2021)
Open
11/10/21-
never
closes
No
age
limit
Permanently open revival window for all
expired claims against all types of defendants
opened on November 10, 2021.38
Ohio 5-Year Window
(2023) Open
10/12/23-
10/11/28
5-year revival window for CSA claims against
the Boy Scouts of America bankruptcy estate
opened on October 12, 2023.39
Oregon Age 40 Limit
(2010)
Age
40
Permanently revived claims up to age 40
against all types of defendants.40
Rhode
Island
Age 53 Limit
(2019)
Age
53
Permanently revived claims up to age 53
against perpetrators only.41
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Utah* 3-Year Window
& Age 53 Limit
(2016)
Closed
5/10/16-
5/9/19
Age
53
Permanently revived claims up to age 53 and
opened a 3-year window, both for claims
against perpetrators and persons criminally
liable. The revivals were held
unconstitutional.42
Vermont Permanent
Window
(2019)
Open
5/28/19-
never
closes
No
age
limit
Permanently open revival window for all
expired claims against all types of defendants
opened on May 28, 2019.43
West
Virginia
Age 36 Limit
(2020)
Age
36
Permanently revived claims up to age 36
against all types of defendants.44
Washington
D.C.
2-Year Window
(2019)
Closed
5/3/19-
5/2/21
2-year window for expired claims against all
types of defendants closed on May 2, 2021.
Window applied to all child sex abuse victims
up to age 40 and, in some circumstances, older
victims and those sexually assaulted as adults.45
III. Analysis of SOL Revival Laws
This section analyzes the 33 jurisdictions that, since 2002, have enacted laws that revive civil suits for
victims of child sex abuse whose SOL has already expired. Revival laws establish a specific period of
time during which survivors can bring previously-expired civil claims to court. There are two types of
revival laws: (1) revival windows and (2) revival age limits. When the revival period is a set amount of
time after the law is passed, it is called a revival window, and claims can be filed while the window is
open. States have opened windows for a few years or permanently. When the revival period is set at a
survivor’s age, it is called a revival age limit, and claims can be filed until a survivor reaches that specific
age. The age states choose ranges from 27-55.
So far, the most popular means of reviving has been with a revival “window”. Some revival laws include
both windows and age limits, while some jurisdictions have chosen to revive via one or the other. Both
types of laws enable adult victims of child sex abuse to sue their abusers and/or the institutions
responsible years after they were abused. These revival laws have been instrumental in giving thousands
of victims across America a long overdue opportunity for justice. They also make states a safer place
for children by educating the public about hidden predators and institutions that endanger children in
their communities.
a. Explanation of Revival Window Laws
California was the first state to enact a revival window after 2002 to help past victims of abuse. Since
then, 23 more states—Delaware, Hawaii, Minnesota, Georgia, Utah, Michigan, New York, Montana,
New Jersey, Arizona, Vermont, North Carolina, Kentucky, Arkansas, Nevada, Louisiana, Maine,
Colorado*, Maryland, Ohio, Indiana, Alabama, Iowa—and three territories—Guam, Washington D.C.,
and Northern Mariana Islands—have opened windows. These windows have varied in length and by
the types of defendants that are permitted to be sued.
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The most effective way to remedy the wrong of having unreasonably short SOLs for so long is to
completely revive all expired claims with a permanently open revival “window.” This is exactly what
Guam did in 2016. Vermont and Northern Mariana Islands did so too in 2021. Maryland opened a
permanent revival window in 2023, but it is not as strong as others because claims are subject to damage
caps and deceased victims are excluded from the window. With these permanent windows, any person
that was sexually abused as a child may sue their abuser or any responsible person or institution when
they are ready. In effect, the law was shifted to accommodate the inherent barriers to disclosure.
The next best windows are those in Arkansas, California, Delaware, Hawaii, Louisiana, New Jersey,
and New York because the windows are or were open for two or more years and clearly apply to claims
against any type of defendant: perpetrators, individuals, institutions, and the government. The less
effective windows are those that only revive claims against perpetrators, like in Georgia, Nevada, and
Utah. The least generous windows are in Alabama, Indiana, Iowa, Michigan, and Ohio. Michigan’s
window only helped victims of Larry Nassar, while Alabama, Indiana, Iowa, and Ohio’s are only helping
victims of the Boy Scouts of America. They leave a gaping hole of injustice for all other victims of
child sex abuse in their states.
States like Massachusetts, Pennsylvania, and Rhode Island do not yet have windows and are
continuing to protect hidden predators and put children at risk.
A window report card grading U.S. States and Territories on the quality of their windows is included
below.
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b. Explanation of Revival Age Limit Laws
The revival age limit laws have opened the courthouse doors to adult victims by allowing them to bring
suits for previously expired claims up until they reach a certain age. The cut-off age varies from West
Virginia’s age thirty-six to Connecticut’s age forty-eight, and age fifty-three in Massachusetts and
Rhode Island. The upside of these laws is that victims younger than the age limit are less pressured to
bring claims within a set few years whether or not they are ready to come forward, which is the case
with temporary windows. The downside is that older victims that are above the cut-off age are still
barred from court. These laws also vary by which defendants are open to suit, with Connecticut as the
best one, reviving suits against any type of defendant, and Massachusetts and Rhode Island with worse
versions that only revive claims against a perpetrator.
c. Explanation of Laws with Both Revival Windows & Age Limits
Some states have revived expired claims of abuse via laws that open temporary windows for victims of
all ages and allow victims to file claims until they reach a certain age, even after the window closes.
The benefit of this hybrid approach is that it gives victims of all ages an opportunity to file claims and
allows more victims into court on a schedule that fits their needs. This approach is particularly helpful
for younger victims who are not fully aware of the abuse or its effects and have not disclosed yet. It
also benefits all victims younger than the age limit who, for whatever reason, are not yet ready to file a
lawsuit against their abuser or those responsible for their abuse before the window closes. However, a
permanent revival window also avoids these issues and is preferable.
Utah was the first state to pass this type of hybrid revival law in 2016 when it attempted to open a threeyear window and enact revival until a victim reaches age fifty-three for claims against perpetrators only.
However, Utah’s revival law was held unconstitutional.46 In 2019, Arizona, California, Montana, and
New Jersey improved on Utah’s approach, and all passed revival laws that included a window and an
age limit for claims against perpetrators and other types of defendants. In 2021, Nevada opened a
permanent revival window for claims against perpetrators only, and revived claims against other
defendants up to age thirty-eight. New Jersey’s law is the strongest and empowers the most victims with
its two-year window and revival up to age fifty-five. Arizona and Montana’s revival laws are less
effective with shorter windows and younger revival age limits, age thirty and twenty-seven, respectively.
d. Revival Law Ranking
This subsection takes a snapshot of all the jurisdictions that have revived claims for victims whose SOL
had already expired. It analyzes all three types of revival laws with a focus on who they help and for
how long. The states are ranked in the chart below based on what aged victim the revival law covers,
the length of time the revival window is open, and which individuals and entities can be sued. Guam,
Maryland, NMI, and Vermont have the best revival laws, because their windows are permanently open
for claims against all defendants. Maryland’s permanent window may appear to rank well alongside
them, but its practical application falls short in comparison. This is due to the presence of damage caps
on claims and the exclusion of deceased victims from the window, making it less helpful than the others
in real-life scenarios. Recently, Alabama, Indiana, Iowa, and Ohio opened limited revival windows only
for claims against the bankruptcy estate of the Boy Scouts of America. These states stand alongside
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Michigan as having the worst windows because they help so few survivors. The following graphic
illustrates the rankings of each jurisdiction’s civil SOL revival law for child sexual abuse claims.
e. Revival Laws Extending into 2024
There are multiple revival laws in effect that can help survivors of child sex abuse gain access to justice.
The U.S. jurisdictions with open revival windows in 2024 include Alabama, Arkansas, Guam, Indiana,
Iowa, Louisiana, Maine, Maryland, Nevada, New York City, NMI, Ohio, and Vermont. The revival
windows in Guam, Maine, Maryland, Nevada, NMI, and Vermont are permanently open, and the end
dates for the other revival windows are in the graphic below. The jurisdictions with age limit revivals in
place in 2024 include Arizona (30), California (40), Connecticut (48), Kansas (31), Massachusetts (53),
Montana (27), Nevada (38), New Jersey (55), Oregon (40), Rhode Island (53), and West Virginia (36).
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1 Alabama: ALA. CODE § 6-2-8(b)(2) (2024); S. B. 18, 2024 Leg., Reg. Sess. (Ala. 2024). 2 ARIZONA: AZ ST § 12-514; “ARIZONA CHILD PROTECTION ACT”, H.B. 2466, 54TH LEG., 1ST REG. SESS. (ARIZ. 2019). 3 Arkansas: Arkansas Act 616; S.B. 204, 94th General Assembly, Reg. Sess. (Arkansas 2023); ARK. CODE ANN. § 16-
118-118. While there is legislative intent to extend the existing window by another two years, the amending language may
have created a 6-month gap during which the window is closed from August 1, 2023 until January 31, 2024, before
opening again on February 1, 2024. 4 Arkansas: “Justice for Vulnerable Victims of Sexual Abuse Act”, Arkansas Act 1036; S.B. 676, 93rd General Assembly,
Reg. Sess. (Arkansas 2021); ARK. CODE ANN. § 16-118-118. 5 CAL. CIV. PROC. CODE § 340.1 (2020); “CHILD VICTIMS ACT,” 2019 Cal. Legis. Serv. Ch. 861 (A.B. 218). 6 Cal. Civ. Proc. Code § 340.35 (1-year window); S.B. 1678, 2004 Gen. Assemb., Reg. Sess. (Cal. 2004); Stogner v.
California, 539 U.S. 607 (2003) (holding California Penal Code section 803 unconstitutional). 7 CAL. CIV. PROC. CODE § 340.1 (2002); 2002 Cal. Legis. Serv. Ch. 149 (S.B. 1779). 8 Aurora Public Schools v. A.S., 2023 CO 39 (Col. June 20, 2023) (holding, “the CSAAA is unconstitutionally
retrospective to the extent that it permits a victim to bring a claim for sexual misconduct based on conduct that predates the
Act and for which previously available causes of action were time-barred” and “clarifying” that “there is no ‘public policy
exception’ to the ban on retrospective laws in article II, section 11 of the Colorado Constitution) affirming Saupe v. Aurora
Public Sch., No. 2022CV30065 (Colo. Dist. Ct. Aug. 3, 2022). 9 “CHILD SEXUAL ABUSE ACCOUNTABILITY ACT,” SB21-088, 73rd Gen. Assemb., 1st Reg. Sess. (Colo. 2021) (effective,
January 1, 2022).
10 CONN. GEN. STAT. § 52-577D; 2002 Conn. Legis. Serv. P.A. 02-138 (S.H.B. 5680). 11 DEL. CODE tit. 18, § 6856; 2010 Del. Laws Ch. 384 (H.B. 326). 12 DEL. CODE tit. 10, § 8145; “CHILD VICTIM’S ACT,” 2007 Del. Laws Ch. 102 (S.B. 29). 13 GA. CODE § 9-3-33.1; “HIDDEN PREDATOR ACT,” 2015 Ga. Laws Act 97 (H.B. 17). 14 7 GUAM CODE ANN. §§ 11306, 11301.1(b); P.L. 33–187:2 (2016). 15 7 GUAM CODE ANN. § 11306(2) (2011); Public Laws No.31-06 (2011). 16 HAW. REV. STAT. § 657-1.8; 2018 Haw. Sess. Laws 98 (S.B. 2719).
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17 HAW. REV. STAT. § 657-1.8; 2014 Haw. Sess. Laws 112 (S.B. 2687). 18 HAW. REV. STAT. § 657-1.8; 2012 Haw. Sess. Laws 68 (S.B. 2588). 19 IND. CODE ANN. §§ 34-11-2-4 (2024); Pub. L. No. 79-2024, 2024 Ind. Legis. Serv. (West). 20 2024 Ia. Legis. Serv. S.F. 2431 (West’s No. 87). 21 S. Sub for HB 2127, 90th Leg., 2023 Reg. Sess. (Kan. 2023). 22 KY. REV. STAT. ANN. § 413.249; 2021 Kentucky Laws Ch. 89 (HB 472). 23 Thompson v. Killary, No. 2022-SC-0308-DG, 2024 WL 646733 (Ky. Feb. 15, 2024) (“We hold that while the statute is
remedial in nature and should be applied retroactively, Appellants hold a vested right in asserting a statute of limitations
defense that is not overcome by the addition of a new triggering event and KRS 413.249 does not provide for the revival of
time-barred claims.”). 24 LA. STAT. ANN. § 9:2800.9; 2024 La. Sess. Law Serv. Act 481 (S.B. 246). 25 LA. STAT. ANN. § 9:2800.9; 2021 La. Sess. Law Serv. Act 322 (H.B. 492). 26 ME. STAT. tit. 14 § 752-C; 2021 Me. Legis. Serv. Ch. 301 (H.P. 432) (L.D. 589). See ME. STAT. tit. 14 § 8103. 27 “THE CHILD VICTIMS ACT OF 2023,” 2023 Md. Laws Ch. 6 (H.B. 1); 2023 Md. Laws Ch. 5 (S.B. 686). 28 MASS. GEN. LAWS ch. 260, § 4C; “SEXUAL ABUSE OF MINORS,” 2014 Mass. Legis. Serv. Ch. 145 (H.B. 4126). 29 MICH. COMP. LAWS § 600.5851b; 2018 Mich. Legis. Serv. P.A. 183 (S.B. 872). 30 MINN. STAT. § 541.073, 2013 Minn. Sess. Law Serv. Ch. 89 (H.F. 681) 31 MONT. CODE § 27-2-216; “TORT ACTIONS–CHILDHOOD SEXUAL ABUSE,” 2019 Mont. Laws Ch. 367 (H.B. 640). 32 NEV. REV. STAT. ANN. §§ 11.215, 41.1396; 2021 Nevada Laws Ch. 288 (S.B. 203). 33 N.J. STAT. ANN. §§ 2A:14-2A & 2A:14-2B; 2019 N.J. Sess. Law Serv. Ch. 120 (S.B. 477). 34 N.Y.C. ADMIN. CODE § 10-1105; (Am. L.L. 2022/021, 1/9/2022, eff. 1/9/2022), available at
https://codelibrary.amlegal.com/codes/newyorkcity/latest/NYCadmin/0-0-0-7248. 35 New York: N.Y. C.P.L.R. 214-g; “Child Victims Act” 2019 Sess. Law News of N.Y. Ch. 11 (S. 2440); Executive Order
No. 202.29 (2020); S.B. 7082, 2020 Leg., Reg. Sess. (N.Y. 2020). 36 N.Y. C.P.L.R. § 214-g (2019). 37 N.C. GEN. STAT. ANN. § 1-17; 2019 North Carolina Laws S.L. 2019-245 (S.B. 199). 38 2021 N. Mar. I. Pub. L. 22-12 (H.B. 22-2). 39 OHIO REV. CODE ANN. § 2305.111; 2023 Ohio Legis. Serv. Ann. 12 (H.B. 35). 40 OR. REV. STAT. ANN. § 12.117; “CHILD ABUSE,” 2009 Or. Legis. Serv. 879 (H.B. 2827). 41 R.I. GEN. LAWS ANN. § 9-1-51; 2019 R.I. Pub Laws 19-83 (19-H 5171B). 42 UTAH CODE ANN. § 78B-2-308; 2016 Utah Laws Ch. 379 (H.B. 279). ). See Mitchell v. Roberts, 469 P.3d 901, 903 (Utah
2020). 43 VT. STAT. ANN. tit. 12, § 522; 2019 Vt. Legis. Serv. No. 37 (H. 330). 44 W. VA. CODE ANN. §55-2-15; 2020 W. Va. Legis. Serv. Ch. 2 (H.B. 4559). 45 D.C. CODE ANN. § 12-301; 2018 D.C. Sess. Law Serv. 22-311 (Act 22-593). 46 Mitchell v. Roberts, 469 P.3d 901 (Utah 2020), reh’g denied (July 13, 2020).