Wilson v. Garcia (1984)
- Docket
- 83-2146
- Decided
- 1984-01-01
Summary
Question: (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? Conclusion: Yes, yes, yes. Justice John Paul Stevens delivered the opinion for the 7-1 majority. The Court held that, in situations where a federal action does not have a statute of limitations, the practice has been to adopt a local limitation as long as that limitation is not inconsistent with a federal law or policy. Looking at the language of Section 1983, the Court determined that Congress intended to create a federal cause of action; therefore, it is up to the federal courts to determine the proper statute of limitation. The Court also determined that the importance of consistency and the diversity of Section 1983 causes of action required a uniform limitation for all causes of action to prevent uncertainty and quarrels over which limitation to apply. Finally, the Court agreed with the appellate court that the three-year personal injury limitation was the best available because of the nature of the remedy afforded by Section 1983. Justice Sandra Day O'Connor wrote a dissenting opinion in which she argued that there need not be a uniform application of limitations to all Section 1983 claims. Rather, each claim should be evaluated individually and assigned a limitation that is most analogous to the specific claim that is brought before the court. Justice Lewis F. Powell, Jr. did not participate in the discussion or decision of the case.