The court of appeals has been inconsistent to some extent in its classification of claims based on sexual abuse. Compare Doe v. F.P., 667 N.W.2d 493, 495, 498 (Minn.App. 2003) (addressing "claims . . . for sexual abuse/sexual exploitation" under the Minnesota criminal sexual conduct statutes, but in the "civil context"), rev. denied (Minn. Oct. 21, 2003), and Park v. Graven. 521 N.W.2d 376, 378 (Minn. App. 1994) (characterizing the plaintiff's claims as alleging "sexual abuse/battery"), with Sarafolean v. Kauffman, 547 N.W.2d 417 (Minn.App. 1996) (alleging both intentional tort claims and negligence claims based on sexual abuse), rev. denied (Minn. July 10, 1996), and M.L. v. Magnuson, 531 N.W.2d 849 (Minn.App. 1995) (addressing negligence and battery claims based on sexual abuse by church pastor), rev. denied (Minn. July 20, 1995), and Roe v. Archdiocese of St. Paul and Minneapolis, 518 N.W.2d 629, 632-33 (Minn. App. 1994) (defining the delayed discovery statute as "appl[ying] a six-year limitations period to both negligence and intentional tort claims"), rev. denied (Minn. Aug. 24, 1994).

Thus, the only sexual abuse victims who would need a window provision to revive claims which would have been time-barred prior to the 1991 amendment are those with claims between two and six years old. Id.; see also Park v. Gravett, 521 N.W.2d 376, 378 (Minn.App. 1994) (confirming that the 1991 window applies only to intentional tort claims between two and six years old), appeal dismissed (Minn. Mar. 3, 1995).