Caseflicks

Supreme Court of the United States • 1989

Owens v. Okure

488 U.S. 235 | 109 S. Ct. 573 | 102 L. Ed. 2d 594 | 1989 U.S. LEXIS 305 | 57 U.S.L.W. 4065

Full access

Unlock the video and quiz

The written brief is free to read below. Subscribe to watch the video explainer and take the quiz.

Create an account Log in

Takeaway

In short, when a State has several personal-injury limitations periods, § 1983 claims borrow the State’s general or residual personal-injury period, not a shorter statute aimed at specified intentional torts.

Background

Tom U. U. Okure sued two State University of New York police officers under 42 U.S.C. § 1983. He alleged that the officers unlawfully arrested him on the SUNY Albany campus, transported him to a detention center, beat him, and caused physical injuries, emotional distress, humiliation, expenses, and the deprivation of his constitutional rights. Okure filed the action 22 months after the January 1984 incident.

The officers argued that the suit was untimely under New York’s one-year limitations period for certain enumerated intentional torts, including assault, battery, false imprisonment, malicious prosecution, libel, slander, and privacy violations. The District Court denied their motion to dismiss, holding that New York’s three-year residual statute for personal-injury claims governed § 1983 actions. The Second Circuit accepted an interlocutory appeal and affirmed. The Supreme Court granted certiorari to resolve disagreement among the federal courts of appeals over which limitations period applies when a State has both specific intentional-tort periods and a general or residual personal-injury period.

Issues

Issue #1

Whether, when state law provides both specific statutes of limitations for enumerated intentional torts and a general or residual statute for personal-injury actions, a § 1983 action is governed by the intentional-tort period or the general or residual personal-injury period.

Holding

The general or residual personal-injury statute of limitations applies to § 1983 actions. Accordingly, New York’s three-year period, rather than its one-year period for specified intentional torts, governed Okure’s claim.

Reasoning

Section 1983 contains no federal statute of limitations. Under 42 U.S.C. § 1988, federal courts therefore borrow an appropriate state limitations rule so long as doing so is consistent with federal law. In Wilson v. Garcia, the Court held that all § 1983 claims should receive one broad characterization—as claims for personal injury—and should generally borrow the State’s personal-injury limitations period.

Wilson rejected a claim-by-claim search for the state cause of action most closely analogous to the particular constitutional violation alleged. That older approach encouraged pleading-based disputes, produced inconsistent results, and left litigants unable to determine the applicable deadline until after litigation began. Uniformity, certainty, and reduced satellite litigation support a simple rule applicable to all § 1983 actions in a State.

Selecting the statute for intentional torts would recreate the very uncertainty Wilson sought to eliminate. States commonly divide intentional torts among several separate limitations provisions, and the particular categories differ from State to State. A rule directing courts to choose an intentional-tort period would force them to decide which of several intentional-tort provisions best fits each federal claim.

By contrast, every State has a readily identifiable general or residual statute that governs personal-injury actions not covered by more specific provisions. Because there is ordinarily only one such general provision, plaintiffs and defendants can determine the governing period with far greater predictability before bringing or defending a § 1983 suit.

The intentional-tort analogy is also substantively too narrow. Section 1983 supplies a broad federal remedy for many injuries to personal rights, including discrimination, unconstitutional employment actions, procedural-due-process violations, mistreatment of schoolchildren, deliberate indifference to prisoners’ medical needs, and unlawful property deprivations. Many such claims do not closely resemble a common-law intentional tort, and even constitutional intent requirements may differ from common-law malice or intent.

The history of § 1983 likewise does not require treating the statute as an intentional-tort remedy. Although Congress responded in part to Klan violence, § 1983 was aimed especially at state officials who failed or refused to protect civil rights. Moreover, the historical analog for many 1871 claims was the broad common-law action on the case for indirect injuries, an ancestor of modern general or residual personal-injury provisions rather than specialized intentional-tort limitations rules.

The Court clarified that Wilson still forbids use of a wholly general catchall statute in the first instance when a State supplies a suitable personal-injury statute. But where a State has multiple personal-injury limitations periods and its residual provision itself covers otherwise unspecified personal-injury claims, that general or residual personal-injury provision is the proper rule to borrow. New York’s three-year statute met that description, so Okure’s suit filed 22 months after the alleged assault was timely.