Supreme Court of the United States
McDonough v. Smith
June 20, 2019588 U.S. 109
Summary
The Supreme Court held that the statute of limitations on a 42 U.S.C. §1983 claim alleging that a special district attorney fabricated evidence and used it to pursue criminal charges does not begin to run until the criminal proceedings terminate in the plaintiff's favor—here, McDonough's December 21, 2012 acquittal—not when the plaintiff learns the evidence is false and suffers a resulting loss of liberty. Adopting the common-law malicious-prosecution analogy and extending the pragmatic concerns articulated in Heck v. Humphrey (avoiding parallel criminal and civil litigation, conflicting judgments, and collateral attacks on criminal judgments), the Court rejected the Second Circuit's earlier-accrual rule and its proposed stays-and-abstention workaround. Because McDonough filed within three years of his acquittal, his claim was timely, and the Second Circuit's judgment was reversed and remanded. Justice Thomas, joined by Justices Kagan and Gorsuch, dissented, contending the writ should have been dismissed as improvidently granted because the specific constitutional right and the elements of the fabricated-evidence claim were never definitively identified.
Holding
- When does the limitations period for a §1983 fabricated-evidence claim accrue?. The statute of limitations for a §1983 fabricated-evidence claim like McDonough's does not begin to run until the criminal proceedings against the §1983 plaintiff have terminated in his favor; McDonough's claim therefore accrued at his December 21, 2012 acquittal, and his December 18, 2015 complaint was timely.
- Whether Wallace v. Kato's rejection of Heck v. Humphrey for false-arrest claims displaces Heck's favorable-termination principles here, and whether pre-acquittal harm fixes the accrual date.. Wallace did not displace the principles in Heck that resolve this case: a fabricated-evidence claim centered on evidence used to secure an indictment and presented at trial directly challenges and necessarily threatens to impugn the prosecution itself, unlike a false-arrest claim with a life independent of any ensuing prosecution, so Heck's rationale extends to ongoing prosecutions. That McDonough suffered harm before his acquittal does not change the result, because the date on which a constitutional injury first occurs is not the only date from which a limitations period may run.
Docket 18-485