Eddie Lawrence Quitugua v. Donna P. Quitugua, et al.

Summary

The District Court of Guam dismissed Eddie Lawrence Quitugua’s amended § 1983 civil rights complaint with prejudice. The court held that the claims were barred by the applicable two-year statute of limitations and declined to impose Rule 11 sanctions, while admonishing Plaintiff regarding alleged misquotations and an unverifiable case citation.

Holdings

1. Plaintiff's § 1983 claims were barred by the applicable two-year statute of limitations because he knew or had reason to know of the alleged injury and its cause no later than December 19, 2021, but did not file suit until September 17, 2025.
2. Plaintiff was not entitled to equitable tolling until January 15, 2025, because he knew of the alleged fraud and resulting injury no later than December 19, 2021.
3. The amended complaint was dismissed with prejudice because the limitations defect could not be cured by further amendment.
4. The court declined to impose Rule 11 sanctions at that time but admonished Plaintiff to ensure the accuracy of future pleadings and citations.

Questions Presented

1. Whether Plaintiff's amended § 1983 claims were barred by the applicable two-year statute of limitations.
2. Whether Plaintiff's allegations supported equitable tolling until January 15, 2025, when an attorney allegedly confirmed the full extent of the fraud.
3. Whether further amendment would be futile.
4. Whether Plaintiff's alleged misquotations and citation of an apparently nonexistent case warranted Rule 11 sanctions.

Disposition

dismissed