WILSON v. GARCIA

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Case Basics
Docket No. 
83-2146
Petitioner 
Richard Wilson and Martin Vigil
Respondent 
Gary Garcia
Advocates
(on behalf of the petitioners)
(on behalf of the respondent)
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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.

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 
Decision: 7 votes for Garcia, 1 vote(s) against
Legal provision: Reconstruction Civil Rights Acts (42 USC 1983)

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.

Cite this Page
WILSON v. GARCIA. The Oyez Project at IIT Chicago-Kent College of Law. 03 June 2015. <http://www.oyez.org/cases/1980-1989/1984/1984_83_2146>.
WILSON v. GARCIA, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1980-1989/1984/1984_83_2146 (last visited June 3, 2015).
"WILSON v. GARCIA," The Oyez Project at IIT Chicago-Kent College of Law, accessed June 3, 2015, http://www.oyez.org/cases/1980-1989/1984/1984_83_2146.