Summary
The First Circuit reversed and remanded a Section 1983 action involving the alleged deprivation of liberty and property interests arising from the termination of a security guard and special police officer appointment in Belfast, Maine. The court held that Maine's six-year statute of limitations for personal injury actions, rather than its two-year limitations period for specified torts, governed the Section 1983 claims. It also held that Maine statutes created a protected property interest in the special police officer position and that factual disputes precluded summary judgment on the alleged deprivation and municipal liability issues.
Topics
Practice areas
Questions Presented
- Which Maine statute of limitations applies to § 1983 actions arising in Maine after Wilson v. Garcia?
- Whether Maine statutes created a constitutionally protected property interest in Small's position as a special police officer of limited jurisdiction.
- Whether the record permitted summary judgment on the question whether defendants caused the deprivation of Small's property interest.
- Whether the City of Belfast could face § 1983 municipal liability based on action by the city manager if he possessed final authority over the appointment.
Holdings
- Maine's six-year general personal-injury limitations period, 14 M.R.S.A. § 752, applies generally to § 1983 actions brought in Maine, rather than the two-year period in 14 M.R.S.A. § 753.
- Maine Revised Statutes §§ 2361(1) and 2362 created a constitutionally protected property interest in Small's position as a special police officer of limited jurisdiction.
- Summary judgment was improper because factual disputes concerning Small's positions and the manner in which he lost them prevented determining whether defendants caused the deprivation.
- The City of Belfast could be liable for unconstitutional action by the city manager if he possessed final authority to revoke Small's special-police appointment.
Key quotations
“Accordingly, we conclude that the Maine six-year limitations period, 14 M.R.S.A. Sec. 752, is the statute applicable generally to "personal injury" actions.” (549)
“We reject this reasoning and hold that these two Maine statutes created a property interest in the plaintiff's position as a special police officer of limited jurisdiction.” (550)
“Accordingly, we believe it is in conformity with the Pembaur decision and the reasoning of Williams v. Butler that liability could attach to the City of Belfast by virtue of unconstitutional action taken on the part of the city manager, if he indeed had the final authority to revoke Small's appointment as a special police officer.” (553)
Factual background
Delbert Small worked as a security guard at Waldo County General Hospital and held an appointment as a special police officer of limited jurisdiction. Belfast City Manager James Murphy informed the hospital that Small had been found possessing a stolen snow plow and that his special-police appointment would be revoked. The hospital discharged Small, and his limited appointment consequently expired. Small alleged that the defendants deprived him of liberty and property interests without notice or a hearing and that the City was liable under 42 U.S.C. § 1983.
Procedural history
The district court dismissed the liberty-interest claim as barred by Maine's two-year statute of limitations. It later granted summary judgment on the property-interest claim, concluding that Small had no constitutionally protected property interest in his special-police-officer appointment and that the defendants had not revoked the appointment. The court also dismissed the City of Belfast because the complaint did not allege an official municipal policy. The First Circuit reversed and remanded all three rulings.
Remand instructions
The district court must consider the merits of the liberty-interest claim under Maine's six-year limitations period, conduct a trial on the property-interest claim, and determine whether the City of Belfast is liable based on the city manager's final authority to revoke Small's appointment.