Owens et al. v. Okure
488 U.S. 235 (1989)
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Rule of Law:
In a state with multiple statutes of limitations for personal injury actions, courts hearing a claim under 42 U.S.C. § 1983 must borrow the state's single general or residual statute of limitations for personal injury, rather than a more specific statute for enumerated intentional torts.
Facts:
- On January 27, 1984, Tom U. U. Okure was on the State University of New York (SUNY) campus in Albany.
- Okure alleged that two SUNY police officers, Javan Owens and Daniel G. Lessard, unlawfully arrested him and charged him with disorderly conduct.
- Okure claimed the officers battered and beat him during the arrest.
- As a result of the encounter, Okure alleged he sustained physical injuries, including broken teeth and a sprained finger, as well as emotional distress and humiliation.
Procedural Posture:
- Tom U. U. Okure sued officers Javan Owens and Daniel G. Lessard in the U.S. District Court for the Northern District of New York under § 1983, 22 months after the alleged incident.
- The officers (defendants) filed a motion to dismiss, arguing the claim was barred by New York's 1-year statute of limitations for intentional torts.
- The District Court (trial court) denied the motion, holding that New York's 3-year residual statute of limitations for personal injury claims applied.
- The District Court certified the question for an interlocutory appeal to the U.S. Court of Appeals for the Second Circuit.
- The Court of Appeals (intermediate appellate court) affirmed the District Court's decision, with one judge dissenting.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.
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Issue:
Where a state has both a specific statute of limitations for certain intentional torts and a general or residual statute for all other personal injury actions, does federal law require a court hearing a § 1983 claim to apply the general or residual statute?
Opinions:
Majority - Justice Marshall
Yes. Where state law provides multiple statutes of limitations for personal injury actions, courts considering § 1983 claims must borrow the general or residual statute for personal injury actions. This approach fulfills the goal set in Wilson v. Garcia to establish a simple, broad, and uniform rule for § 1983 limitations periods, thereby promoting predictability and minimizing litigation. The court reasoned that choosing among various state statutes for intentional torts would reintroduce the same confusion and inconsistency that Wilson sought to eliminate, as states have numerous, varied statutes for different intentional torts. Furthermore, the broad remedial purpose of § 1983, which covers a wide spectrum of claims beyond common-law intentional torts, is better served by a general statute rather than one tied to a narrow and often imprecise analogy to specific torts.
Analysis:
This decision provides a crucial clarification to the rule established in Wilson v. Garcia, which held that § 1983 claims borrow a state's personal injury statute of limitations. By mandating the use of the general or residual personal injury statute, the Court created a bright-line rule that enhances predictability and uniformity across all jurisdictions. This holding prevents federal courts from engaging in time-consuming analyses of state law to find the 'most analogous' tort, thus streamlining litigation. The decision favors a broader limitations period, reflecting a policy preference for providing federal civil rights plaintiffs with an effective remedy and sufficient time to bring their claims.
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