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Rape Lawsuit Against Marilyn Manson Dismissed, But ‘Jane Doe’ Given Another Chance to Explain Her ‘Repressed Memories’


A California judge has dismissed a sexual assault lawsuit filed by an anonymous plaintiff against singer Marilyn Manson (whose legal name is Brian Warner).

Los Angeles County Superior Court Judge Gregory Keosian (appointed to the bench in 2002 by former governor Gray Davis) based the dismissal on timing: “Jane Doe’s” lawsuit was filed after California’s statute of limitations had run.

California’s recently-extended statute dictating the acceptable timeline for sexual assault cases requires that for adult victims, civil lawsuits must be filed within ten years from the date of the alleged incident. In addition, the statute also has what is known as a “delayed discovery rule,” which allows victims to file civil actions for damages for three years after an injury was or reasonably should have been discovered. That three-year period specifically allows for individuals with delayed psychological injuries or other illnesses to seek legal compensation.

Jane Doe’s lawsuit was filed in May 2021 and alleged that Warner raped Doe in 2011. Doe claimed that until recently, she had repressed memories of Warner raping her, threatening to kill her, making her watch a disturbing video, and forcing her to drink urine. Warner moved to dismiss by arguing that the statute of limitations had expired. Judge Keosian agreed and ruled that Doe’s claim of repressed memories was not sufficient to invoke the delayed discovery rule.

Although Warner won this particular legal battle, it does not mean that the entire legal war between Jane Doe and Marilyn Manson is over for good. Rather, the judge gave the plaintiff 20 days to amend her complaint and provide additional details about her claim. If Doe can allege enough details to entitle her to use the delayed discovery rule, her lawsuit may well advance to the next level.

In addition to Jane Doe’s lawsuit, Warner is also the subject of multiple other legal actions. Warner’s former assistant Ashley Walters¬†sued Warner for sexual assault, battery, and harassment. Game of Thrones actor Esme Blanco and model Ashley Morgan Smithline sued Warner for sexual abuse. These legal actions¬† occurred after actor Evan Rachel Wood publicly accused Warner of grooming, brainwashing, and brutal abuse. Although Warner has not been criminally charged in relation to these allegations, he was the subject of a domestic violence investigation.

Publicly, Warner has maintained his innocence as to all the allegations against him. His attorney did not respond to request for comment.

[image via Frazer Harrison/Getty Images]

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Elura is a columnist and trial analyst for Law & Crime. Elura is also a former civil prosecutor for NYC's Administration for Children's Services, the CEO of Lawyer Up, and the author of How To Talk To Your Lawyer and the Legalese-to-English series. Follow Elura on Twitter @elurananos