Summary
The Supreme Court held that federal courts adjudicating claims under 42 U.S.C. § 1983 must borrow the state statute of limitations governing general or residual personal-injury actions when a state has multiple personal-injury limitation periods. The Court rejected borrowing statutes applicable to enumerated intentional torts because that approach would create confusion and fail to reflect the broad range of § 1983 claims. The Court affirmed application of New York's three-year residual personal-injury limitations period to the respondent's claim.
Topics
Practice areas
Questions Presented
- When a state has multiple statutes of limitations governing personal-injury actions, including a statute for specified intentional torts and a general or residual personal-injury statute, which limitations period must federal courts borrow for claims under 42 U.S.C. § 1983?
Holdings
- When state law provides multiple statutes of limitations for personal-injury actions, a court considering a § 1983 claim must borrow the state's general or residual personal-injury statute of limitations, rather than the statute governing specified intentional torts.
- New York's three-year general personal-injury statute, N.Y. Civ. Prac. Law § 214(5), governs Okure's § 1983 claim, making the complaint timely.
Key quotations
“We accordingly hold that where state law provides multiple statutes of limitations for personal injury actions, courts considering § 1983 claims should borrow the general or residual statute for personal injury actions.” (488 U.S. at 250)
“Because “§ 1983 claims are best characterized as personal injury actions,” we held that a State's personal injury statute of limitations should be applied to all § 1983 claims.” (488 U.S. at 240-241)
Factual background
Okure alleged that two State University of New York police officers unlawfully arrested him on January 27, 1984, on the SUNY campus in Albany and charged him with disorderly conduct. He alleged that the officers forcibly transported him to a detention center, battered and beat him, and caused emotional distress, physical injuries, humiliation, and other damages. He filed his § 1983 damages action on November 13, 1985, approximately 22 months after the incident.
Procedural history
Okure filed suit 22 months after the alleged unlawful arrest and police beating. The District Court held that New York's three-year residual personal-injury limitations period applied rather than the one-year period for enumerated intentional torts, and denied dismissal. The Second Circuit affirmed, and the Supreme Court affirmed the appellate judgment.