## Facts

- Gary Garcia sued New Mexico State Police officer Richard Wilson and police chief Martin Vigil under 42 U.S.C. § 1983, alleging an unlawful arrest and severe physical abuse.
- Garcia alleged Vigil knew of Wilson’s prior misconduct and failed to take corrective action.
- Garcia filed his § 1983 complaint about two years and nine months after the alleged events.
- New Mexico potentially supplied multiple limitation periods: a 2-year period under the Tort Claims Act for certain suits against governmental entities and employees, a 3-year period for personal injury actions, and a 4-year residual period for actions not otherwise provided for.
- Defendants argued the 2-year Tort Claims Act period applied; Garcia argued a longer period applied.

## Issues

1. Whether federal or state law governs how § 1983 claims are characterized for selecting the applicable state statute of limitations.
2. Whether all § 1983 claims within a state must receive a single, uniform characterization for limitations purposes, rather than a claim-by-claim matching to state causes of action.
3. Which New Mexico limitations period is most appropriate for § 1983 actions.

## Decision

- The Supreme Court affirmed the judgment applying New Mexico’s 3-year personal injury limitations period to § 1983 actions.
- The Court held federal law governs the characterization of § 1983 claims for limitations purposes.
- The Court required a single, broad characterization for all § 1983 claims within a state.
- The Court characterized § 1983 claims as actions for personal injury, making the state personal injury period the appropriate borrowed limitations period.

## Legal Principles

- When Congress provides no limitations period for a federal cause of action, courts borrow an appropriate state statute of limitations, subject to federal policy reflected in 42 U.S.C. § 1988.
- Under § 1988, characterization of a § 1983 claim for limitations purposes is a federal question; the borrowed state limitations period (and related tolling rules) applies only if consistent with federal law.
- For limitations purposes, § 1983 claims are generally treated as personal injury actions, and the state’s general personal injury statute of limitations should be applied uniformly to all § 1983 claims in that state.
- Limitations rules that discriminate against or unduly burden the federal civil-rights remedy are inconsistent with § 1983 and § 1988.

## Conclusion

The Court required uniform treatment of § 1983 actions for limitations purposes by using federal law to characterize all such claims as personal injury actions and borrowing each state’s general personal injury limitations period, which in New Mexico was three years.


Wilson v. Garcia, 471 U.S. 261 (1985)