LOCATION: New Mexico State Police Headquarters
DOCKET NO.: 83-2146
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: United States Court of Appeals for the Tenth Circuit
CITATION: 471 US 261 (1985)
ARGUED: Jan 14, 1985
DECIDED: Apr 17, 1985
Bruce M. Hall - on behalf of the petitioners
Steven G. Farber - on behalf of the respondent
Facts of the case
Gary Garcia alleged that in 1979 he was unlawfully arrested, beaten, and tear-gassed by the petitioner, Richard Wilson, who was a New Mexico State Police officer. Garcia also alleged that Martin Vigil, the Chief of the State Police, knew Wilson had attacked citizens on several occasions but had failed to take action. Garcia sued for a violation of Section 1983 of the United State Code, a civil rights statute that creates a civil cause of action for the deprivation of rights. The petitioners argued that this Section 1983 claim should be subject to the two-year statute of limitations that applied to a similar cause of action found in the New Mexico Tort Claims Act (Act). If that statute of limitations were applied, this case could not proceed because the complaint was not filed until two years and nine months after the alleged beating. The district court held that the two-year statute of limitations recommended by petitioners did not apply because it was not sufficiently related to the nature of the right being enforced by Garcia's claim. Instead, the district court held that a different cause of action in the Act was more closely related to this Section 1983 claim and applied that cause of action's four-year statute of limitations. The U.S. Court of Appeals for the Tenth Circuit affirmed the district court's ruling but held that actions brought under Section 1983 are essentially an injury to personal rights; therefore, the three-year statute of limitations that applies to all personal injury actions in New Mexico should apply to Section 1983 claims.
(1) Are claims under Section 1983 of the United States Code federal claims?
(2) Should a uniform statute of limitations apply to all the causes of action that give rise to Section 1983 violations?
(3) Are state-level personal injury claims sufficiently similar to violations of civil rights claimed under Section 1983 such that they should have the same statute of limitations?
Media for Wilson v. Garcia
Audio Transcription for Oral Argument - January 14, 1985 in Wilson v. Garcia
Warren E. Burger:
We will hear arguments next in Wilson and Vigil against Garcia.
Mr. Hall, I think you may proceed whenever you are ready.
Bruce M. Hall:
Mr. Chief Justice, and may it please the Court, as with the case just submitted, as Your Honor's questions indicate, this, too, is a case involving the application of a state statute of limitations to a 1983 civil rights action.
It arises out of an incident of alleged police brutality.
The petitioners, who were the defendants below, moved to dismiss this action which had been filed some two and one-half years after the incident occurred, and moved to dismiss it on the basis of a state statute of limitation which provided that all actions against government entities and public employees for their torts must be filed within two years.
It is clear that had the case been filed in state court in New Mexico, that that limitation provision would have been applied and this case dismissed on petitioners' motion.
The lower federal courts, both the District Court and the Circuit Court, have refused to follow the decision of the state's highest court and apply that two-year limitation.
The petitioners submit that this is wrong.
It is wrong under the language of Section 1988, which provides the rule of decision.
It is wrong under the characterization and application of 1988 by this Court.
It is wrong, quite simply, because the state judicial decision supplied the state rule of law, and unless inconsistent with the United States Constitution or the policies of deterrence and compensation underlying 1983, that state rule of decision is to be borrowed.
The cases of the Court on this point are quite clear.
There is no basis for distinguishing between a state court judicial decision and an express legislative determination which would by its terms apply to 1983 actions.
As a matter of settled jurisprudence, a construction by a state court of a state limitation is itself part of the statute, and does not represent simply a common law decision.
Given that fact, I think it is clear that 1988 intended to borrow and have govern, as it states, not only the statutes of limitations which the state courts would apply, but those statutes of limitations, general, which the state's highest court has said are expressly applicable.
Sandra Day O'Connor:
Mr. Hall, the Court of Appeals, because it took a global approach to this 1983 problem, simply didn't find it necessary to decide what statute New Mexico would apply here, and the District Court below apparently thought the New Mexico Tort Claims Act, the two-year statute, was inapplicable.
Is that right?
And you think the District Court was wrong in its view?
Bruce M. Hall:
Justice, the Circuit Court, I agree, never really reached the question of what was state legislative intent as expressed in the state court opinion.
Now, the District Court opinion is quite interesting.
The District Judge acknowledges that had there been an express legislative provision saying that this two-year limitation is applicable to actions against governmental entities and public employees for their torts and constitutional torts, that that should have been followed under Section 1988.
The District Court essentially disagreed with the New Mexico Supreme Court's interpretation of New Mexico's own limitation.
Now, the District Judge also found freedom, as did the Circuit Court, in the principle that because we are applying a limitation to a 1983 action, and because characterizations of that action are involved, that that is finally a federal question, and that it is the freedom of this federal question, and that it is the freedom of this federal question which allows the federal courts to ignore the state rule decision.
Sandra Day O'Connor:
Well, you do concede, of course, I suppose, that there is a federal question involved here on characterization.
Bruce M. Hall:
Now, in this case, I said I disagreed, and I am going to take it back just a bit.
Where characterization is necessary, certainly that characterization is a federal question.
Where you have an express legislative determination, or where you have the application of the general limitation clearly defined by statelaw, I don't believe that characterization is necessary.
It is still a federal question.
It is simply irrelevant under that analysis.