Hanley v. Citizens Bank of Massachusetts
Massachusetts Superior Court
2001 WL 717106 (2001)
James Hanley (plaintiff), a security guard, was beaten by robbers (the "Hole-in-the-Roof Gang") who had broken into Citizens Bank of Massachusetts (defendant) overnight; a bank alarm had sounded and police responded but could not enter because no bank representative arrived to let them in. Hanley didn't learn this fact — that a bank employee failed to show up when the alarm sounded — until years later at the robbers' federal criminal trial, and sued Citizens for negligent hiring, training, and supervision ten years after the incident. Citizens moved to dismiss on statute-of-limitations grounds.
Whether the discovery rule provides that the statute of limitations does not run against a claim until an event or events have occurred that were reasonably likely to place the plaintiff on notice that someone may have caused the injury.