McDonough v. Smith
2019 United States Supreme Court opinion / From Wikipedia, the free encyclopedia
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McDonough v. Smith, 588 U.S. ___ (2019), was a United States Supreme Court case from the October 2018 term. In a 6–3 ruling, the Court held that the 3-year statute of limitations for a fabrication of evidence civil lawsuit under section 1983 of the Civil Rights Act begins to run when the criminal case ends in the plaintiff's favor.[1]
McDonough v. Smith | |
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Argued April 17, 2019 Decided June 20, 2019 | |
Full case name | Edward G. McDonough v. Youel Smith, Individually and as Special District Attorney for the County of Rensselaer, New York (aka Trey Smith) |
Docket no. | 18-485 |
Citations | 588 U.S. ___ (more) 139 S. Ct. 2149; 204 L. Ed. 2d 506 |
Case history | |
Prior | Motion to dismiss granted, McDonough v. Smith, No. 1:15-cv-01505, 2016 WL 5717263 (N.D.N.Y. Sept. 30, 2016); motion for reconsideration denied, 2017 WL 1901962 (N.D.N.Y. May 8, 2017); affirmed, 898 F.3d 259 (2d Cir. 2018); cert, granted, 139 S. Ct. 915 (2019). |
Holding | |
The statute of limitations for a §1983 fabricated-evidence claim began to run when the criminal proceedings end in the §1983 plaintiff's favor. | |
Court membership | |
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Case opinions | |
Majority | Sotomayor, joined by Roberts, Ginsburg, Breyer, Alito, Kavanaugh |
Dissent | Thomas, joined by Kagan, Gorsuch |
Laws applied | |
42 U.S.C. § 1983 |
This case was notable as a victory for criminal defendants; the precedent it set would make it easier to sue prosecutors and police for fabricating evidence against defendants.[2] The Court's ruling also resolves a circuit split between United States Court of Appeals for the Second Circuit and other federal appeals courts.[3]