Anthony Monroe v. Terry Conner, et al.

Congress enacted 42 U.S.C. § 1983 as a means to hold state actors accountable for violating federal constitutional and statutory rights. Congress did not, however, specify every rule governing claims filed under Section 1983, instead instructing courts to fill in the gaps by borrowing “suitable” federal law or, where no such federal law exists, pertinent state law that is “not inconsistent with the Constitution and laws of the United States.” 42 U.S.C. § 1988(a). Because Congress did not specify a statute of limitations for Section 1983 claims, the Court has held that courts may borrow state statutes of limitations as long as the borrowed statute does not frustrate the “federal interest[s]” underpinning Section 1983. Burnett v. Grattan, 468 U.S. 42, 47-49 (1984). Applying that standard, this Court has held that courts adjudicating Section 1983 claims should ordinarily borrow the forum state’s statute of limitations governing personal injury actions, see Owens v. Okure, 488 U.S. 235, 249-50 (1989), which in most states is at least two years. The Court expressly left open the question whether applying a state’s one-year limitations period to Section 1983 claims would be “inconsistent with federal interests.” Id. at 251 n.13. This case presents the question that the Court expressly left unanswered in Owens: Whether applying a state’s one-year statute of limitations to Section 1983 claims is inconsistent with the federal statutory scheme and the interests that it is designed to uphold (and if so, how courts should determine the appropriate limitations period).