In In re: Naval Chaplaincy, (D DC, Aug. 23, 2023), the D.C. federal district court held that plaintiffs have not shown that the running of the statute of limitations on their free exercise claims should be tolled because of fraudulent concealment. In the case, which has been in litigation for nearly 25 years, non-liturgical Protestant chaplains alleged discrimination against them by selection boards that control promotions and early retirements of Navy chaplains. (See prior posting.)