The American Civil Liberties Union of Louisiana and Latham & Watkins LLP filed a petition for a writ of certiorari in the Supreme Court of the United States on behalf of Anthony Monroe, an individual who was unlawfully beaten by the Louisiana State Police on his way home from work.
The United States District Court for the Western District of Louisiana dismissed Mr. Monroe’s Section 1983 action against Defendants Terry Conner, Richard Matthews, Lamar Davis, and Chavez Cammon as time-barred under Louisiana’s one-year residual statute of limitations. The Fifth Circuit affirmed the district court’s decision, noting that it was bound by existing Supreme Court precedent to apply a state’s residual statute of limitations to Section 1983 claims and that “only the Supreme Court” could clarify how lower courts should evaluate the practical frustration of a victim’s Section 1983 claim in states with statutes of limitations periods that are excessively short. Since the Fifth Circuit’s decision, Louisiana has lengthened its residual limitations period for claims filed after June 2024, but Mr. Monroe’s claim remains time-barred under Louisiana law, and other jurisdictions in the country continue to apply one-year limitations periods to Section 1983 claims.
Before the Supreme Court, the ACLU of Louisiana and Latham argued that the one-year statute of limitations period that governs Mr. Monroe’s case is inconsistent with the federal interests underlying Section 1983, a federal civil rights cause of action enacted amid state-sanctioned violence during Reconstruction. This case provides the Court an opportunity to resolve the question it expressly reserved in Owens v. Okure, 488 U.S. 235 (1989): whether a one-year limitations period is inconsistent with federal interests. As the petition describes, a one-year limitations period frustrates the ability of claimants to enforce their federal rights, especially for victims of police brutality who often experience emotional trauma, physical injuries, and legal obstacles that render the filing of their claims within one year practically impossible. Borrowing a longer limitations period from the four-year, federal “catch-all” statute of limitations under 28 U.S.C. 1658 or state law limitations periods for analogous claims would better effectuate the federal interests underpinning Section 1983.
Three different groups have filed amicus briefs urging the Court to grant Mr. Monroe’s petition for a writ of certiorari.
The Law Enforcement Accountability Project (LEAP) outlines the consequences of imposing a one-year statute of limitations for federal civil rights claims, including the possibility that many victims will not be able to file their claims at all and the resulting drop in community trust and reliance on police. LEAP describes why a longer limitations period may actually reduce the total number of filed claims by providing more time for internal police investigations of the claims.
The Institute for Justice (IJ) explains why a one-year limitations period is insufficient for claimants to properly develop their claims, especially given procedural barriers such as the legal doctrines of qualified immunity and municipal liability that require plaintiffs to extensively research their claims before filing. IJ argues that clarifying that a one-year limitations period is too short would not lead to additional litigation, but rather may improve the quality of claims filed.
Finally, the Orleans Public Defenders (OPD) details the practical difficulties of claimants filing Section 1983 claims within one year given the need for extensive pretrial investigation and the potential added toll of recovering from physical injuries and defending against criminal charges. OPD suggests that the federal catch-all limitations period should control Section 1983 claims.
Mr. Monroe is represented by Nora Ahmed at the ACLU of Louisiana and the team of Roman Martinez, Blake Stafford, and Nikita Kansra at Latham & Watkins LLP.