Supreme Court of the United States

Wilson v. Garcia

April 17, 1985471 U.S. 261

Summary

The Court held that federal law governs how claims under 42 U.S.C. § 1983 are characterized for statute-of-limitations purposes, while state law supplies the applicable limitations period and related rules. It further held that each State should use one uniform characterization for all § 1983 claims and that such claims are best treated as personal-injury actions. Applying that rule, the Court affirmed use of New Mexico's three-year personal-injury limitations period, making the respondent's action timely.

Holding

  • Whether federal or state law governs characterization of a § 1983 claim for statute-of-limitations purposes.. Federal law governs the characterization of a § 1983 claim because characterization is derived from the elements and purpose of the federal cause of action. State law governs only the length of the limitations period and closely related questions such as tolling and application.
  • Whether § 1983 claims should receive a uniform characterization within each State.. Each State must select one most appropriate statute of limitations for all § 1983 claims rather than applying different periods based on the particular facts or legal theory of each claim.
  • Which New Mexico limitations period applies to the respondent's § 1983 claim.. § 1983 claims are best characterized as actions for personal injuries, so New Mexico's three-year limitations period for injury to the person or reputation applies. Because the complaint was filed within three years, it was timely.

Docket 83-2146

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