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Civil rights Keyed to Jeffries, 5th Ed.
Wilson v. Garcia
Citation:
471 U.S. 261 (1985)Facts
In April 1979, respondent Gary Garcia was allegedly subjected to an unlawful arrest by petitioner Wilson, a New Mexico State Police officer, who “brutally and viciously” beat him and sprayed his face with tear gas. Garcia also claimed that petitioner Vigil, the Chief of the New Mexico State Police, had notice of Wilson’s “violent propensities” but failed to properly train or supervise him. In January 1982, approximately two years and nine months after the incident, Garcia filed a § 1983 action in federal district court seeking damages for the deprivation of his constitutional rights and for personal injuries. The defendants moved to dismiss the complaint as time-barred under New Mexico’s 2-year statute of limitations for actions against state officials under the Tort Claims Act. The New Mexico Supreme Court had previously held in DeVargas v. New Mexico that this 2-year limitation applied to § 1983 actions. However, the federal district court rejected this precedent, holding that characterization of § 1983 claims is a matter of federal law, and applied New Mexico’s 4-year residual statute of limitations. The Tenth Circuit Court of Appeals, in an en banc decision, affirmed but applied New Mexico’s 3-year statute for personal injury actions, concluding that all § 1983 claims should be uniformly characterized as actions for injury to personal rights.
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