New Precedent: Ohio’s Two-Year Personal-Injury Statute Governs Title IX Claims

1. Introduction

In Eszter Pryor v. The Ohio State University, No. 24-3812 (6th Cir. Jun. 2, 2025), the Sixth Circuit resolved a recurring question: which state statute of limitations applies to federal Title IX claims? Eszter Pryor, a former diving club member at Ohio State University (OSU), alleged that her coach sexually abused her when she was sixteen. Nearly eight years later, she sued OSU under Title IX, claiming deliberate indifference to her abuse. The district court dismissed her action as time-barred under Ohio’s two-year personal-injury statute. Pryor appealed, urging application of Ohio’s twelve-year child-sex-abuse statute instead. The Sixth Circuit affirmed, holding that Ohio Revised Code § 2305.10(A)’s two-year limitations period governs Title IX actions, and that her claim accrued—and thus expired—two years after her eighteenth birthday.

2. Summary of the Judgment

The Sixth Circuit, in an opinion by Judge Davis, affirmed the district court’s grant of summary judgment. It held that:

The applicable limitations period for Pryor’s Title IX claim is Ohio Revised Code § 2305.10(A), the two-year personal-injury statute.
This uniform rule follows binding Sixth Circuit precedent (Lillard, Bannister, Snyder-Hill, Garrett) and Supreme Court decisions interpreting § 1983 limitations (Wilson v. Garcia; Owens v. Okure).
Pryor’s claim accrued on her eighteenth birthday (July 2015) and she filed in January 2022, well beyond the two-year window.
Ohio’s longer child-sex-abuse statute (§ 2305.111(C)) does not govern Title IX actions; applying it would undermine uniformity and predictability.

Because no tolling or accrual delay was asserted, her Title IX claim is time-barred, and the court affirmed.

3. Analysis

3.1 Precedents Cited

The court relied on both Supreme Court and Sixth Circuit authority, as well as decisions from sister circuits, to establish the controlling rule:

Wilson v. Garcia (471 U.S. 261, 1985): § 1983 claims must be “characterized in the same way” for limitations purposes—courts should apply a single, broad statute of limitations rather than parsing the precise legal theory.
Owens v. Okure (488 U.S. 235, 1989): All § 1983 claims borrow the forum state’s personal-injury limitations period, rejecting narrower analogies to specific intentional-tort provisions.
Lillard v. Shelby Cnty. Bd. of Educ. (76 F.3d 716, 1996): Sixth Circuit applied state personal-injury statute to Title IX claims, establishing the borrowing approach for implied federal causes of action.
Snyder-Hill v. Ohio State Univ. (48 F.4th 686, 2022) & Bannister v. Knox Cnty. Bd. of Educ. (49 F.4th 1000, 2022): Sixth Circuit confirmed that Ohio’s two-year personal-injury statute (§ 2305.10(A)) governs accrual and timeliness of Title IX suits in Ohio federal courts.
Garrett v. Ohio State Univ. (60 F.4th 359, 2025): Recent decision reaffirming § 2305.10(A) applies to Title IX.
Federal Cases from Other Circuits: Uniformly apply forum personal-injury statutes to Title IX claims (Curto, Bougher, King-White, Stanley, Varnell, M.H.D., Egerdahl, etc.).

3.2 Legal Reasoning

The Sixth Circuit’s reasoning proceeds in three steps:

Identify Borrowed Limitations Period: Title IX contains no express statute of limitations. Under federal practice, courts “borrow” the most analogous state limitations period for implied federal causes of action (Wilson; Owens).
Determine Analogy: The State’s general personal-injury statute is the appropriate analogue for Title IX claims, as recognized repeatedly by the Sixth Circuit and sister circuits.
Accrual and Application: Under Ohio law, a minor’s personal-injury claim “accrues” on the plaintiff’s 18^th birthday. Pryor turned eighteen in July 2015 and thus had until July 2017 to file. She filed in January 2022, five years too late.

The court rejected Pryor’s invitation to select a different Ohio statute (§ 2305.111(C)’s twelve-year child-sex-abuse period) based on the particular facts. Doing so would fragment limitations rules, create uncertainty, and conflict with the Supreme Court’s mandate for uniform treatment of implied rights of action.

3.3 Impact

This decision carries substantial implications:

Uniform Deadline: Plaintiffs nationwide can no longer shop for the longest state child-abuse statute when suing under Title IX—they must comply with the jurisdiction’s personal-injury period.
Predictability for Defendants: Institutions will know precisely how long they can be sued under Title IX—generally the same window as other tort defendants.
Consistency with § 1983 Jurisprudence: Reinforces parallelism between Title IX and § 1983, both implied federal remedies for discrimination.
Tolling and Accrual Practices: Future litigants must pay close attention to accrual rules (e.g., a minor’s claim accuess at 18) and any doctrines that might toll or extend limitations.
Legislative and Institutional Response: States or Congress concerned about prolonged exposure to Title IX liability might consider explicit tolling rules or longer limitations windows in the federal statute itself.

4. Complex Concepts Simplified

Limitations Period vs. Accrual: A “limitations period” is the deadline for filing suit. “Accrual” occurs when a claim arises—here, the date a minor plaintiff turns 18 if injury and cause were already known.
Borrowing Rule: Federal courts “borrow” the most analogous state statute of limitations for federal claims lacking their own deadlines (e.g., Title IX, § 1983).
Personal-Injury Analogy: Title IX claims, like § 1983 claims, remedy personal injuries (discrimination-induced harms), so the general personal-injury statute is the logical choice.
Tolling Doctrines: Rules that can pause or extend a limitations clock (e.g., discovery rule, minority tolling), but none were asserted successfully in Pryor’s case beyond the accrual‐at-eighteen rule.
Uniformity Principle: To avoid confusion and inequity, courts apply a single, broad limitations period rather than different windows for different factual sub‐claims.

5. Conclusion

Eszter Pryor v. OSU cements the rule that Title IX tort claims in Ohio federal courts are subject to the State’s two-year personal-injury limitations period (Ohio Rev. Code § 2305.10(A)), accruing when a minor plaintiff turns eighteen. By aligning Title IX with § 1983 principles and rejecting application of a longer child-abuse statute, the Sixth Circuit ensures consistent, predictable deadlines for all parties. Institutions gain clarity on their exposure period, and prospective plaintiffs must act promptly once their injuries have accrued. This decision reaffirms the balance between Title IX’s remedial goals and the legitimate interest in repose that limitations statutes serve.