The Ninth Circuit Court of Appeals has reopened a case accusing an Okanogan County sheriff’s deputy of coercing a woman he once arrested into a years-long sexual relationship, ruling that each alleged act of misconduct reset the statute of limitations.
In a unanimous decision Tuesday, the three-judge panel revived Christina St. Clair’s lawsuit alleging discrimination, harassment under Washington’s Law Against Discrimination, and civil rights violations under the 14th Amendment by Deputy Sheriff Isaiah Holloway and the county itself.
From Dismissal to Revival
U.S. District Judge Thomas O. Rice had dismissed St. Clair’s case in February 2024, citing Washington’s three-year statute of limitations. St. Clair claimed the coercion began in 2014, but she filed her lawsuit in September 2023.
The Ninth Circuit, however, pointed to allegations that Holloway’s misconduct continued until 2021. That meant, judges ruled, that claims from after September 2020 remain within the statutory window.
Circuit Judge M. Margaret McKeown, writing for the panel, stressed that each incident stood on its own:
“Had Holloway made no sexual overtures until 2020, those acts would surely be independent violations.”
McKeown warned that forcing victims to lump separate incidents together under a single time bar would wrongly shield ongoing abusers.
