id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
iiclr-21269	Peltz-Steele, Richard J.	Wrongs, Rights, and Remedies: A Yankee Romp in Recent European Tort Law	2016	73	.pdf	application/pdf	26041	1271	57	California law was amended in 1990 to be more permissive of child sex-abuse claims, allowing them until the plaintiff’s twenty-sixth birthday, and a court in 1994 ruled the extension inapplicable to “ancillary” negligence claims—respondeat superior, negligent hiring, and negligent supervision—against third parties to the abuse, namely the dance studio that employed the defendant instructor.148 Later, in 1998 and again in 2003, the legislature further relaxed the limitations period as to employers and supervisors.149 As to apportionment, U.S. courts in the comparative fault era have declined to effect liability allocation with intentional actors in the mix, because comparative fault is not a defense to intentional torts—though the Restatement (Third), Apportionment cracks the door open to such mixing.150 Nevertheless, once comparative fault is properly implicated, most U.S. courts include empty chair in apportionment.151 Shifting an empty chair’s liability allocation to the plaintiff when the chair is empty because of the plaintiff’s procedural constraints comports with the rule that only innocent plaintiffs are preferred in liability reallocations for absent parties.152 147 Joseph M. Winsby & Elaine D. Walter, Applying the Statutes of Limitations in Institutional Childhood Sex Abuse Cases, FLA. The court calculated that the national minimum wage, an annual €10,500, multiplied by 3% permanent disability, and multiplied by 16 years’ remaining work-life for the 48-year-old plaintiff, resulted in an award conveniently approximate to €5000.40 The Maltese delegate characterized the case as “a missed opportunity” to recognize non-pecuniary damages in civil liability.41 The default rule of U.S. tort law being to value a person in terms of his or her economic productivity, U.S. courts too have struggled to value homemaking fairly (at least since modern recognition of gender equality).	cache/iiclr-21269.pdf	txt/iiclr-21269.txt