AB v State of Queensland & Anor

[2022] QCA 109 · McMurdo JA (Fraser and Mullins JJA agreeing)

In plain language

The plaintiff (referred to as AB) was a single mother who became a foster carer in 2006. A teenage boy placed in her home by a foster-care agency and the State went on to sexually abuse her young daughter. The shock caused AB to develop a generalised anxiety disorder, depression and a post-traumatic stress condition. Years later she sued the agency and the State, arguing they knew of the boy's history of sexualised behaviour but failed to warn her. Because her claim was filed well outside the three-year limit, she needed a court extension. The District Court refused it.

On appeal, the Court of Appeal found that AB only learned of solid proof that the defendants had actual knowledge of the boy's history when two internal reports were disclosed in March 2020. The court ruled this was a critical new fact she could not reasonably have known earlier, extended the limitation period, and allowed her claim to go ahead. This decision was procedural - it did not decide the claim or award any damages.

Incident & injury

Psychological injury suffered by foster carer after foster child placed in her care sexually abused her biological daughter; respondents failed to disclose the foster child's prior history of sexualised behaviour

Body regions
Psychiatric
Diagnoses
Generalised Anxiety Disorder, Major Depressive Disorder (secondary), Adjustment Disorder with features of Post Traumatic Stress Disorder
Incident date
1 August 2006
Location
Queensland (foster home)

Quick facts

Date of judgment
17 June 2022
Proceeding
Appeal
Plaintiff outcome
Successful
Plaintiff age at injury
~41 (inferred)
Occupation
Foster carer (single mother) Community & Personal Service Worker

Outcome

The Court of Appeal granted leave to appeal and allowed the appeal, setting aside the District Court's refusal to extend time. It held a material fact of a decisive character (proof that the respondents had actual knowledge of XY's history of sexualised behaviour) was not within the appellant's means of knowledge until 16 March 2020, and extended the limitation period to 16 March 2021 so the personal injury claim could proceed.

Key issues

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AB v State of Queensland & Anor [2022] QCA 109

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