Wilson v. Garcia
Annotate this Case
471 U.S. 261 (1985)
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U.S. Supreme Court
Wilson v. Garcia, 471 U.S. 261 (1985)
Wilson v. Garcia
Argued January 14, 1985
Decided April 17, 1985
471 U.S. 261
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. 471 U. S. 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. 471 U. S. 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. 471 U. S. 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. 471 U. S. 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. 471 U. S. 280. POWELL, J., took no part in the consideration or decision of the case.