The Ninth Circuit has breathed new life into the Sex Harassment Wash Sheriff lawsuit, ruling that claims brought by Christina St. Clair against Okanogan County and Deputy Sheriff Isaiah Holloway can proceed, after a lower court had dismissed them on statute-of-limitations grounds.
A unanimous three-judge panel said Tuesday that each alleged act of misconduct by Holloway effectively reset the clock. St. Clair claims the deputy coerced her into a seven-year sexual relationship that began after he arrested her in 2014, extending through 2021.
U.S. District Judge Thomas O. Rice had tossed out her claims in February 2024, ruling that she waited too long to sue. But the appeals court said allegations of sexual misconduct after September 2020 remain actionable.
Judges Say Clock Resets with Each Act
Writing for the panel, Circuit Judge M. Margaret McKeown said, “Even if misconduct stretches back years, each new act stands as its own violation.” She warned that adopting a rigid cutoff would allow abusers to hide behind time limits while continuing harassment.
The panel also reinstated older claims, noting St. Clair alleged she delayed filing because of her drug addiction, fear of criminal repercussions, and Holloway’s leverage as a law enforcement officer. “Awareness of imbalance is not the same as awareness of abuse,” McKeown added.
