Anthony Monroe v. Terry Conner, et al.
SocialSecurity
1. This case raises an important question of federal law regarding the appropriate statute of limitations for claims under 42 U.S.C. § 1983: whether a forum state's limitations period for personal injury claims could be so short that applying it to federal civil rights claims undermines the federal interests underlying Section 1983. During the Reconstruction Era, Congress enacted the Civil Rights Act of 1871, including Section 1983, to hold state actors accountable for violations of federal constitutional and statutory rights. Because the statute did not contain every rule required to adjudicate claims filed thereunder, Congress directed courts to borrow pertinent rules from state law or common law. Under the framework articulated by this Court in Burnett v. Grattan, 468 U.S. 42 (1984), a court borrowing a forum state's statute of limitations to apply to claims under Section 1983 may do so only after ensuring that the state's limitations period is not "inconsistent with the Constitution and laws of the United States." Id. at 48 (quoting 42 U.S.C. § 1988). In conducting this analysis, courts must account for the interests underlying Section 1983, including "compensation of persons whose civil rights have been violated[] and prevention of the abuse of state power." Id. at 53.
More than 30 years ago, in Owens v. Okure, 488 U.S. 235 (1989), this Court reaffirmed Burnett's analytical framework and held that, where state law furnishes multiple limitations periods for personal injury actions, a court considering a Section 1983 claim should borrow the forum state's residual, or general, personal injury statute of limitations. Id. at 249-50. Because the Court concluded that New York's general three-year limitations period applied to the claim at issue, it expressly declined to address the question of whether applying a one-year limitations period would be "inconsistent with federal interests." Id. at 251 n.13 (citing Burnett, 468 U.S. at 61 (Rehnquist, C.J., concurring in the judgment)).
The forthcoming petition for certiorari in this case presents the Court with an opportunity to conclusively resolve this question of utmost importance to civil rights claimants and the legitimacy of the country's federal system. In the decision below, the Fifth Circuit affirmed the application of Louisiana's one-year residual statute of limitations to Section 1983 claims. Op. 4. Today, more than 18 million people reside in jurisdictions in which Section 1983 claims are subject to one-year statutes of limitations. Given that Section 1983 secures a broad range of constitutional protections, the issue of whether a one-year limitations period contravenes the federal interests underlying Section 1983 has ramifications for hundreds of potential claimants per year. The Court's intervention on this question is warranted, as lower courts will otherwise continue to apply one-year (or shorter) limitations periods in the absence of this Court's guidance. This petition will provide an excellent vehicle for this Court to clarify this critical aspect of litigation under Section 1983—a "most important, and ubiquitous, civil rights statute." Wilson v. Garcia, 471 U.S. 261, 266 (1985) ("conflict, confusion, and uncertainty concerning the appropriate statute of limitations to apply" to Section 1983 "provided compelling reasons for granting certiorari").
2. This case squarely presents the question whether a one-year limitations period contravenes the federal interests
Whether a state's one-year statute of limitations for civil rights claims under 42 U.S.C. § 1983 impermissibly undermines the federal interests of compensating victims and preventing state power abuse