Wilson v. Garcia
United States Supreme Court
471 U.S. 261 (1985)
- Written by Whitney Kamerzel , JD
Facts
Gary Garcia (plaintiff) sued Richard Wilson, a police officer, and Martin Vigil, the police chief (defendants) in federal district court, alleging that Wilson wrongfully arrested and beat Garcia and that Vigil knew about Wilson’s violent propensities and failed to address them. Garcia brought his claim under 42 U.S.C. § 1983 two years and nine months after the claim arose. A recent New Mexico Supreme Court case held that New Mexico’s two-year Tort Claims Act statute of limitations applied to § 1983 claims because it was the closest applicable statute of limitations. Using this precedent, Wilson and Vigil moved to dismiss the case because more than two years had passed since Garcia’s claim arose. The district court denied the motion, arguing that New Mexico’s catchall four-year limitations period applied. The court of appeals reversed and held that New Mexico’s three-year limitations period for personal-injury claims applied. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Stevens, J.)
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