471 U.S. 261 (1985), 83-2146, Wilson v. Garcia
|Docket Nº:||No. 83-2146|
|Citation:||471 U.S. 261, 105 S.Ct. 1938, 85 L.Ed.2d 254, 53 U.S.L.W. 4481|
|Party Name:||Wilson v. Garcia|
|Case Date:||April 17, 1985|
|Court:||United States Supreme Court|
Argued January 14, 1985
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE
Respondent brought an action in Federal District Court under 42 U.S.C. § 1983 against petitioners, a New Mexico State Police officer and the Chief of the State Police, seeking damages for deprivation of respondent's constitutional rights allegedly caused by an unlawful arrest and brutal beating by the officer. The complaint was filed two years and nine months after the claim purportedly arose. Petitioners moved to dismiss on the ground that the action was barred by the 2-year statute of limitations of the New Mexico Tort Claims Act. The District Court denied the motion, holding that the New Mexico statute providing a 4-year limitations period for "all other actions not herein otherwise provided for" applied to § 1983 actions brought in the State. On an interlocutory appeal, the Court of Appeals affirmed the denial of the motion to dismiss, but held that the appropriate statute of limitations for § 1983 actions brought in New Mexico was the New Mexico statute providing a 3-year limitations period for personal injury actions.
Held: Section 1983 claims are best characterized as personal injury actions, and hence the Court of Appeals correctly applied the 3-year statute of limitations applicable to such actions. Pp. 266-280.
(a) Federal rather than state law governs the characterization of a § 1983 claim for statute of limitations purposes. This conclusion is supported by the federal interest in uniformity and the interest in having firmly defined, easily applied rules. The language of 42 U.S.C. § 1988 that the law to be applied in adjudicating civil rights claims shall be in "conformity with the laws of the United States, so far as such laws are suitable," directs that the matter of characterization should be treated as a federal question. Only the length of the limitations period, and related questions of tolling and application, are to be governed by state law. This interpretation is also supported by the instruction in § 1988 that state law shall only apply "so far as the same is not inconsistent with" federal law. Pp. 268-271.
(b) A simple, broad characterization of all § 1983 claims for statute of limitation purposes, rather than differing evaluations depending upon the varying factual circumstances and legal theories presented in each case, best fits the statute's remedial purposes. The statute is fairly construed as a directive to select, in each State, the one most appropriate statute of limitations for all § 1983 claims. The federal interests in
uniformity, certainty, and the minimization of unnecessary litigation all support the conclusion that Congress favored such a simple approach. Pp. 271-275.
(c) In this case, the characterization of the § 1983 claim as a personal injury action for statute of limitations purposes is supported by the nature of the § 1983 remedy and by the federal interest in ensuring that the borrowed limitations period not discriminate against the federal civil rights remedy. The characterization of all § 1983 actions as involving claims for personal injuries minimizes the risk that the choice of a state statute of limitations would not fairly serve the federal interests vindicated by 1983. Pp. 276-279.
731 F.2d 640, affirmed.
STEVENS, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, MARSHALL, BLACKMUN, and REHNQUIST, JJ., joined. O'CONNOR, J., filed a dissenting opinion, post, p. 280. POWELL, J., took no part in the consideration or decision of the case.
STEVENS, J., lead opinion
JUSTICE STEVENS delivered the opinion of the Court.
In this case, we must determine the most appropriate state statute of limitations to apply to claims enforceable under § 1 of the Civil Rights Act of 1871,1 which is codified in its present form as [105 S.Ct. 1940] 42 U.S.C. § 1983.
On January 28, 1982, respondent brought this § 1983 action in the United States District Court for the District of New Mexico seeking
money damages to compensate him for the deprivation of his civil rights guaranteed by the Fourth, Fifth and Fourteenth Amendments to the United States Constitution and for the personal injuries he suffered which were caused by the acts and omissions of the [petitioners] acting under color of law.
App. 4. The complaint alleged that, on April 27, 1979, petitioner Wilson, a New Mexico State Police officer, unlawfully arrested the respondent, "brutally and viciously" beat him, and sprayed his face with tear gas; that petitioner Vigil, the Chief of the New Mexico State Police, had notice of Officer Wilson's allegedly "violent propensities," and had failed to reprimand him for committing other unprovoked attacks on citizens; and that Vigil's training and supervision of Wilson was seriously deficient. Id. at 6-7.
The respondent's complaint was filed two years and nine months after the claim purportedly arose. Petitioners moved to dismiss on the ground that the action was barred by the 2-year statute of limitations contained in § 41-4-15(A) of the New Mexico Tort Claims Act.2 The petitioners' motion was supported by a decision of the New Mexico Supreme Court which squarely held that the Tort Claims Act provides "the most closely analogous state cause of action"3 to § 1983, and that its 2-year statute of limitations is therefore applicable
to actions commenced under § 1983 in the state courts. DeVargas v. New Mexico, 97 N.M. 563, 642 P.2d 166 (1982). In addition to the 2-year statute of limitations in the Tort Claims Act, two other New Mexico statutes conceivably could apply to § 1983 claims: § 37-1-8, which provides a 3-year limitation period for actions "for an injury to the person or reputation of any person";4 and § 37-1-4, which provides a 4-year limitation period for "all other actions not herein otherwise provided for."5 If either of these longer statutes applies to the respondent's § 1983 claim, the complaint was timely filed.
In ruling on the petitioners' motion to dismiss, the District Court concluded that the New Mexico Supreme Court's decision in DeVargas was not controlling because "the characterization of the nature of the right being vindicated under § 1983 is a matter of federal, rather than state, law."6 After reviewing various approaches to the question, the District Court concluded that "§ 1983 actions are best characterized as actions based on statute."7 Because there is no specific New Mexico statute of limitations governing such claims, the District [105 S.Ct. 1941] Court held that § 37-1-4, the residual 4-year statute, applied to § 1983 actions brought in New Mexico. The court denied the petitioners' motion to dismiss, and certified an interlocutory appeal under 28 U.S.C. § 1292(b).8
The Court of Appeals for the Tenth Circuit accepted the appeal. App. 2. After argument before a three-judge panel, the case was set for reargument before the entire court. In a unanimous en banc opinion, the Court of Appeals affirmed the District Court's order denying the motion to dismiss the complaint. 731 F.2d 640 (1984).
The Court of Appeals' reasoning was slightly different from the District Court's. It agreed that the characterization of a § 1983 claim is a matter of federal law, and that the New Mexico Supreme Court's decision in DeVargas was therefore not conclusive on the question. 731 F.2d at 643, 651, n. 5. The opinion reviewed the varying approaches of the United States Courts of Appeals,9 and concluded that, even though § 1983 actions encompass a wide variety of fact situations and legal theories,
[a]ll of the federal values at issue in selecting a limitations period for section 1983 claims are best served by articulating one uniform characterization describing the essential nature underlying all such claims.
Id. at 650. Distilling the essence of the § 1983 cause of action, the court held that every claim enforceable under the statute is, in reality, "an action for injury to personal rights," and that "[h]enceforth, all § 1983 claims in [the] circuit will be uniformly so characterized for statute of limitations purposes." Id. at 651. Accordingly, the appropriate statute of limitations for § 1983 actions brought in New Mexico was the 3-year statute applicable to personal injury actions.10 It followed that the respondent had filed his complaint in time.
The Court of Appeals acknowledged that its holding is at odds with the New Mexico Supreme Court's decision in DeVargas. It also commented on the extensive conflict in the Federal Courts of Appeals:
the courts vary widely in the methods by which they characterize a section 1983 action, and in the criteria by which they evaluate the applicability of a particular state statute of limitations to a particular claim. The actual process used to select an appropriate state statute varies from circuit to circuit, and sometimes from panel to panel.
731 F.2d at 643. "Few areas of the law stand in greater need of firmly defined, easily applied rules than does the subject of periods of limitations." Chardon v. Fumero Soto, 462 U.S. 650, 667 (1983) (REHNQUIST, J., dissenting). Thus, the conflict, confusion, and uncertainty concerning the appropriate statute of limitations to apply to this most important, and ubiquitous, civil rights [105 S.Ct. 1942] statute provided compelling reasons for granting certiorari. 469 U.S. 815 (1984). We find the reasoning in the Court of Appeals' opinion persuasive, and affirm.
The Reconstruction Civil Rights Acts do not contain a specific statute of limitations governing § 1983 actions11 -- "a void which is commonplace in federal statutory law." Board of Regents v. Tomanio, 446 U.S. 478, 483 (1980). When...
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