What constitutes an abuse of a confidential position?

And, at para. 65: In cases of incest there is, of course, a grievous abuse of a position of confidence. I will have more to say later about the fiduciary nature of the parent-child relationship, but for now it is enough to say that incest is clearly an abuse of a confidential position. As the authorities make clear, incest is really a double wrong -- the act of incest itself is followed by an abuse of the child's innocence to prevent recognition or revelation of the abuse; see Evans v. Eckelman, supra. I should add that given the nature of the concealment in abuse cases, namely, that the abuser compels the complicity of the victim in denying the harm done to her, it may be that the doctrine can operate in a [page119] tort as well as fiduciary context to toll the limitation period because of the deliberate attempts at concealment on the part of the abuser.