Owens v. Okure

In January 1984, Tom Okure (plaintiff) was arrested by two State University of New York (SUNY) police officers, including Javan Owens (defendant). In November 1985, Okure sued Owens in federal court pursuant to 42 U.S.C. § 1983 for violating Okure’s constitutional rights. Specifically, Okure alleged that Owens forcibly transported him to a detention center, battered and beat him, and forced him to suffer emotional distress, physical harm, and embarrassment. Owens moved to dismiss the complaint on statute-of-limitations grounds. Because Congress did not specify a statute of limitations for § 1983 claims, under this Court’s precedent, the district court was required to borrow New York’s statute of limitations for personal-injury actions. However, New York had two potentially relevant statutes of limitations for personal-injury claims: (1) a one-year limitations period for intentional torts like assault, battery, and false imprisonment and (2) a three-year residual statute of limitations for other personal-injury suits. Owens argued that the district court should borrow the one-year period, under which Okure’s claim was time-barred. Per Owens, the intentional-tort limitations period was most appropriate because § 1983 claims are most similar to intentional torts. The district court disagreed, ruling that the three-year period applied and thus that Okure’s suit was timely. The court of appeals affirmed. Owens appealed.