But Keosian found that the woman’s claim of repressed memories around the alleged rape -- which the ruling allows “is common for sexual-assault victims” -- was “not sufficient” to invoke California’s so-called “delayed-discovery” rule, which effectively postpones the start date of the statute of limitations if the plaintiff can prove that they first became aware of the injury within two years of filing their complaint, regardless of when the incident itself took place.
“Here, the Complaint alleges only that Plaintiff repressed unspecified memories at some point before reading an article in February 2021,” Keosian’s ruling reads. “The complaint alleges neither when the repression began — such as immediately after the events took place, or outside the limitations period — nor its nature or extent, such as what memories were repressed or the extent to which Plaintiff was prevented from recalling them.”
As previously mentioned, the ruling does give Doe some wiggle room, affording her 20 days to amend and refile her complaint to address Keosian’s concerns.
“Marilyn Manson wants to silence our client about her rape,” said Doe’s attorneys, Adam Wolf and Tracey Cowan of Peiffer Wolf, in a statement sent to Billboard. “He tried to use technical legal arguments to get her case thrown out altogether. The judge thoughtfully analyzed the case law, and rightfully held that her case can go forward, so long as she amends her Complaint to add some additional details. We intend to amend with those additional details very shortly, and look forward to the opportunity to make Manson answer for his actions.”
An attorney for Manson declined to comment.
In her original complaint, which was filed May 28, Doe claimed that over the course of their relationship, the musician subjected her to "degrading acts of sexual exploitation, manipulation, and psychological abuse." She alleged that when she went to return the keys to Manson’s apartment following their breakup, Manson pushed her to the floor, and "with her face down on the carpet, and his hands on top of her,” raped her. Doe further claimed that after the alleged assault, Manson threatened to kill her and “bragged that he would get away with it” if he followed through.
Manson is currently being sued for sexual assault by three other women, including Game of Thrones actress and former girlfriend Esme Bianco, his former personal assistant Ashley Walters and another ex-girlfriend, Ashley Morgan Smithline. The lawsuits all arrived after Manson’s ex-girlfriend, actress Evan Rachel Wood, publicly named him as her abuser in February.
Manson has denied all accusations against him. In July, he filed to dismiss Bianco’s suit, claiming that she and the other women's accusations were part of a "coordinated attack."
Stories about sexual assault allegations can be traumatizing for survivors of sexual assault. If you or anyone you know needs support, you can reach out to the Rape, Abuse & Incest National Network (RAINN). The organization provides free, confidential support to sexual assault victims. Call RAINN's National Sexual Assault Hotline (800.656.HOPE) or visit the anti-sexual violence organization's website for more information.