Springfield Township School District v. Knoll

PETITIONER: Springfield Township School District
RESPONDENT: Knoll
LOCATION: New Mexico State Police Headquarters

DOCKET NO.: 82-1889
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: United States Court of Appeals for the Third Circuit

CITATION: 471 US 288 (1985)
ARGUED: Jan 14, 1985
DECIDED: Apr 17, 1985

ADVOCATES:
Charles Potash - on behalf of the petitioners
Robert H. Chanin - on behalf of the respondent

Facts of the case

Question

Media for Springfield Township School District v. Knoll

Audio Transcription for Oral Argument - January 14, 1985 in Springfield Township School District v. Knoll

Warren E. Burger:

We will hear arguments first this morning in Springfield Township School District against Knoll.

Mr. Potash, you may proceed whenever you are ready.

Charles Potash:

Mr. Chief Justice, and may it please the Court, this case squarely presents to the Court the question whether a state statute of limitations applicable to the commencement of judicial proceedings should be disregarded in a Section 1983 suit solely on the ground that the limitation period, six months, is per se unreasonably short, and consequently inconsistent with the Constitution and laws of the United States.

Respondent commenced suit on April 21st, 1981, to redress alleged discrimination on the basis of sex by her employer, the School District of Springfield Township.

One of her claims sought relief under Section 1983.

In the alternative, respondent sought relief under Section 703 of the Civil Rights Act of 1964.

Under her theory, the last act of discrimination occurred in September of 1980, some seven or eight months earlier, when a man was appointed as assistant superintendent, a job for which she had not applied.

The school district defendants moved for summary judgment, one of the grounds being that the Section 1983 claim was barred by the Pennsylvania state statute of limitations governing certain actions against public officials.

The District Court agreed.

The Court of Appeals in a panel decision reversed the dismissal of the 1983 claim on the ground that the six-month statute of limitations was so short as to be inherently inconsistent with the policies fostered by the Civil Rights Act.

The school district defendants applied for rehearing, and the application was denied, with four judges voting to grant the rehearing.

Now, there is no question in this case that the statute at issue was properly identified as the most appropriate state statute of limitations.

Therefore the question left for resolution is what the Court labeled in the recent case of Burnett versus Cratton as the third step in a Section 1983 inquiry, that is, is the state statute inconsistent with federal law?

I submit that this inquiry should be confined to a determination whether the state statute discriminates against federal rights or provides so short a time so as to effectively preclude litigating a civil rights claim.

It is clear that the Pennsylvania statute does not directly conflict with the Civil Rights Act.

The statute does not discriminate against federal claims.

It was not enacted with any intent to discriminate against federal claims, nor is there any hostility toward any civil rights action.

It applies to both state and federal claims.

A more cogent reason is found in the holding of the Third Circuit which held it was the analogous statute of limitations.

Implicit in this finding was that the state and federal law claims were being treated equally.

Here there is no basis for rejection of the Pennsylvania statute on the ground that it discriminates against federal civil rights actions.

The six-month statute of limitations at issue in this case is one expressly applicable to the commencement of judicial proceedings rather than administrative proceedings.

The limitation period applies to judicial remedies enforceable in court in the first instance.

It does not limit who may bring suit.

It does not preclude money damages or injunctive relief.

For these reasons, its enactment should raise a presumption that the legislature took into account the burden of the parties to the suit governed by the limitation, and the practicalities involved in litigating civil rights claims, and found the limitation period to be a reasonable one.

The determination of the Pennsylvania legislature that a six-month period is a reasonable one within which to commence litigation, whether in a state or federal court, is given support by the holding of the Court in DelCostello versus the International Brotherhood of Teamsters.

That case impliedly recognized that a six-month limitation period was sufficient for the commencement of relatively complex federal litigation.

That case cuts across any conclusion that the practicalities of litigation necessarily mean that a six-month period is an unreasonable time in which to bring a federal cause of action.

An inquiry into the record of this case would disclose no basis for finding that the six-month limitation period was unreasonable.