Michigan's Court of Appeals ruled in July 2026 that a childhood sexual abuse lawsuit against Grace Christian Reformed Church of Grand Rapids can proceed, overturning a 2024 dismissal that had blocked the claim. The court determined that Michigan's 2018 statute of limitations reform, which extended the filing deadline for abuse survivors to age 28, applies retroactively to plaintiff Marian Ippel's case.
The decision revives a claim that had been dismissed under Michigan's older rules. Ippel alleged that deacon Roger Wagenmaker and another individual abused her at age 3 to 4 in 2006–2007, and she recovered those memories in 2020 before filing suit in 2024 at age 21—outside the former deadline but within the new one. The appeal victory means her case now advances to trial in Kent County Circuit Court.
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Table of Contents
- The Timeline of Dismissal and Recovery
- Why the Statute of Limitations Matters Here
- What the Allegations Involve
- The Path Forward and Potential Precedent
- What Survivors Should Know About Timing
The Timeline of Dismissal and Recovery
The original complaint faced an immediate barrier: timing. Ippel filed the lawsuit in 2024 at age 21, claiming she had recovered memories of the abuse in 2020. Under Michigan law as written before 2018, survivors had to file before turning 19—a deadline she had passed long before remembering the harm.
The Kent County Circuit Court applied the old rule and dismissed the case in 2024. But Michigan had changed its law four years before her filing. In 2018, the state amended its statute of limitations to allow survivors until age 28 to bring suit, recognizing that trauma recovery often happens years after abuse occurs. The Circuit Court declined to apply this newer rule to Ippel's claim, treating her as bound by the old deadline instead.
Why the Statute of Limitations Matters Here
A statute of limitations sets a deadline for filing a lawsuit. Without it, defendants could face claims decades after events occur, making evidence collection and defense impossible. But rigid deadlines can also shield institutions from accountability when victims need time to process trauma or recover memories.
Ippel's case hinges on whether the 2018 amendment—which nearly doubled the filing deadline from age 19 to age 28—should reach backward to protect plaintiffs who had not yet filed when the law changed. The Court of Appeals ruled that it does apply retroactively to her claims because she was within the new extended window when the statute was amended. The court distinguished her situation from older cases that had fully expired under the previous rules before any reform took effect.
What the Allegations Involve
Ippel alleges that deacon Roger Wagenmaker and another individual abused her when she was 3 to 4 years old in 2006–2007, taking her to the church basement after a children's worship service. Her claims also include institutional failure to protect her—the allegation that the church and its leadership should have known of or prevented the abuse.
The defendants named in the lawsuit are Grace Christian Reformed Church of Grand Rapids and the Christian Reformed Church in North America (CRCNA), a Protestant Calvinist denomination based in Grand Rapids. Institutional liability cases like this often focus on whether leaders failed to implement safeguards, investigate reports, or remove known risks from contact with children.
The Path Forward and Potential Precedent
The case now proceeds to trial in Kent County Circuit Court. Ippel's legal team has requested a jury trial, which means a jury will decide questions of fact—whether the abuse occurred, whether the defendants were aware of risks, and whether their actions or inaction fell below the duty to protect children.
The outcome may establish precedent for how Michigan courts apply the 2018 statute of limitations reforms to other survivors whose claims were previously dismissed. Depending on how the trial court and any subsequent appeals handle institutional liability, the decision could also influence how churches, schools, and youth organizations assess their legal exposure to delayed-disclosure abuse claims. Cases like this often settle before trial, but settlement terms are typically confidential and do not create binding precedent.
What Survivors Should Know About Timing
If you were abused as a child in Michigan, the 2018 law change may protect your ability to sue even if you file after turning 19. You now have until age 28 to initiate a claim. Memory recovery is often gradual and nonlinear—you do not need to remember everything or have physical evidence to begin an investigation.
Consult a personal injury attorney specializing in abuse cases before the deadline passes. Early consultation will not obligate you to file immediately but will help you understand your options, the strength of potential claims, and the timeline. Many survivors find that therapy or recovery work comes before pursuing litigation, and the law accommodates delayed filing for exactly this reason.