George Washington University v. Jabari Stafford

This Court has recognized that, where a federal statute creates a claim but does not specify a deadline to assert it, Congress presumptively “intended that the courts apply the most closely analogous statute of limitations under state law.” DelCostello v. International Brotherhood of Teamsters, 462 U.S. 151, 158 (1983); see, e.g., Holmberg v. Armbrecht, 327 U.S. 392, 395 (1946). Respondent brought this suit against petitioner, alleging a violation of Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seq.— Spending Clause legislation that prohibits discrimination based on race, color, or national origin in a program that receives federal funding. Title VI contains no express limitations period for private suits. The district court held that the state law most closely analogous to Title VI is the District of Columbia Human Rights Act—a statute that proscribes the same conduct, has the same purpose, offers the same remedies, applies in the same contexts, and is enforced through the same processes as Title VI. The court of appeals reversed. It construed this Court’s precedents as requiring the application of the state-law limitations period for personal-injury claims to any federal civil-rights statute lacking its own express deadline. The court of appeals therefore held that respondent’s claim is subject to the District’s catchall limitations period that encompasses personal-injury claims for which no other time bar is specified. The question presented is as follows: Whether courts should reflexively borrow the state-law general limitations period applicable to all personal-injury claims to govern any claim alleging unlawful discrimination under a federal statute that does not specify its own limitations period.