Michael Curtis Broughton v. Town of Normal, Illinois; Normal Police Department; McLean County Unit 5 School District; and Individual Vice Detectives/Handlers (John Does 1-5)

Summary

The United States District Court for the Central District of Illinois dismissed Michael Curtis Broughton’s civil-rights action under 42 U.S.C. § 1983 with prejudice as untimely. The court held that alleged events from 1991 and 2002–2004 were not saved by discovery, minority, military-service, equitable, or continuing-tort tolling doctrines. The court declined supplemental jurisdiction over the state-law intentional-infliction-of-emotional-distress claim, denied or mooted the remaining motions, and directed the Clerk to close the case.

Holdings

1. Section 1983 claims brought in Illinois are subject to a two-year limitations period, and the plaintiff's claims based on events occurring in 1991 and 2002-2004 were untimely when filed in 2026.
2. The plaintiff's allegations concerning delayed discovery, trauma-related amnesia, third-party threats, and military service did not make his Section 1983 claims timely.
3. After dismissing all claims within its original federal-question jurisdiction, the court declined to exercise supplemental jurisdiction over the intentional-infliction-of-emotional-distress claim.
4. The court denied further leave to amend because any amendment would be futile in light of the statute-of-limitations defect.

Questions Presented

1. Whether the plaintiff's Section 1983 claims were barred by Illinois's two-year statute of limitations.
2. Whether minority, discovery, equitable, continuing-tort, or Servicemembers Civil Relief Act tolling rendered the Section 1983 claims timely.
3. Whether the court should exercise supplemental jurisdiction over the intentional-infliction-of-emotional-distress claim after dismissing all federal claims.
4. Whether the plaintiff should receive another opportunity to amend his complaint.
5. Whether the plaintiff's in forma pauperis motion satisfied the requirements for proceeding without prepayment of fees.

Disposition

dismissed