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McDonough v. Smith

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Supreme Court of the United States
McDonough v. Smith
Term: 2018
Important Dates
Argument: April 17, 2019
Decided: June 20, 2019
Outcome
Reversed and remanded
Vote
6-3
Majority
Chief Justice John G. Roberts • Ruth Bader Ginsburg • Stephen Breyer • Samuel Alito • Sonia Sotomayor • Brett Kavanaugh
Dissenting
Clarence Thomas • Elena Kagan • Neil Gorsuch


McDonough v. Smith is a case argued before the Supreme Court of the United States on April 17, 2019, during the court's 2018-2019 term. It came on a writ of certiorari to the United States Court of Appeals for the 2nd Circuit.[1]

The case concerned 42 U.S.C. Section 1983 and whether the statute of limitations for fabrication-of-evidence claims begins to run when the proceedings end or when the defendant becomes aware of the fabrication.

On June 20, 2019, the U.S. Supreme Court reversed the 2nd Circuit's judgment in a 6-3 opinion penned by Justice Sonia Sotomayor. Justice Clarence Thomas filed a dissenting opinion, joined by Justices Elena Kagan and Neil Gorsuch. Click here for more information about the opinion.

HIGHLIGHTS
  • The case: Edward McDonough, an election official in New York, was indicted on 74 felony counts of ballot forgery. Special district attorney Youel Smith prosecuted McDonough. A first trial ended in a mistrial. McDonough was acquitted in a second trial in 2012. McDonough filed a lawsuit in 2015 under 42 U.S.C. § 1983 claiming Smith fabricated evidence and used it against him in the previous trials. The Northern District of New York ruled McDonough filed the lawsuit too late because the statute of limitations had run out. The 2nd Circuit upheld the district court's ruling, disagreeing with past decisions the 3rd Circuit, 9th Circuit, and 10th Circuit made in other cases.
  • The issue: "Whether the statute of limitations for a Section 1983 claim based on fabrication of evidence in criminal proceedings begins to run when those proceedings terminate in the defendant's favor (as the majority of circuits has held) or whether it begins to run when the defendant becomes aware of the tainted evidence and its improper use (as the Second Circuit held below)."[2]
  • The outcome: In a 6-3 decision, the court reversed the 2nd Circuit's judgment and remanded the case. The court upheld a decision from a majority of circuit courts, holding the statute of limitations for a Section 1983 claim based on fabrication of evidence in criminal proceedings begins to run when those proceedings terminate in the defendant's favor.[3]


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • June 20, 2019: The U.S. Supreme Court reversed the 2nd Circuit's ruling and remanded the case
    • April 17, 2019: Oral argument
    • January 11, 2019: U.S. Supreme Court agreed to hear the case
    • October 12, 2018: Petition filed with U.S. Supreme Court
    • August 3, 2018: 2nd Circuit affirmed the ruling of the Northern District of New York
    • September 30 and December 30, 2016: Northern District of New York dismisses McDonough's claim
    • December 18, 2015: McDonough files a lawsuit under 42 U.S.C. § 1983 against Smith
    • December 21, 2012: McDonough acquitted in second trial

    Background

    In 2009, Edward McDonough was the Democratic commissioner of the Rensselaer County elections board in New York. During the 2009 Working Families Party primary election in Troy, New York, several individuals associated with the Democratic and Working Families Party forged signatures and provided false information on absentee ballot applications and absentee ballots. McDonough approved the applications. He later said he did not know they were forged.[4][5]

    The New York state court appointed Youel Smith as a special district attorney to investigate and prosecute those involved in the forged applications. McDonough claimed Smith participated in a scheme to frame McDonough for the crimes, including by fabricating evidence. On January 28, 2011, a grand jury indicted McDonough on 74 felony counts. A first trial ended in a mistrial. In a second trial, McDonough was acquitted on December 21, 2012.[4][5][6][7]

    On December 18, 2015, McDonough filed a lawsuit under 42 U.S.C. § 1983, charging Smith and 10 other defendants with violating his due process rights and for malicious prosecution. The defendants filed a motion to dismiss the due process claim. They argued the three-year statute of limitations for fabrication-of-evidence claims had passed because McDonough had known about the allegedly false evidence three years before he filed the Section 1983 lawsuit. McDonough argued the statute of limitations began running after his acquittal in 2012.[4][5]

    The U.S. District Court for the Northern District of New York granted the defendant's motion to dismiss, citing the statute of limitations. The U.S. Court of Appeals for the 2nd Circuit affirmed the district court's ruling on the grounds that the statute of limitations on a fabrication-of-evidence claim begins to run when the plaintiff has "reason to know of the injury which is the basis of his action." In its ruling, the 2nd Circuit disagreed with decisions from the 3rd Circuit, 9th Circuit, and 10th Circuit in other cases.[4][5]

    42 U.S.C. § 1983

    Title 42 of the United States Code Section 1983 (42 U.S.C. § 1983) is a federal statute that allows individuals to sue the government for civil rights violations. Cases brought under Section 1983 are sometimes referred to as "Section 1983 claims."[8]

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    • Whether the statute of limitations for a Section 1983 claim based on fabrication of evidence in criminal proceedings begins to run when those proceedings terminate in the defendant's favor (as the majority of circuits has held) or whether it begins to run when the defendant becomes aware of the tainted evidence and its improper use (as the Second Circuit held below).

    Outcome

    On June 20, 2019, the U.S. Supreme Court reversed the 2nd Circuit's judgment in a 6-3 opinion penned by Justice Sonia Sotomayor. Justice Clarence Thomas filed a dissenting opinion, joined by Justices Elena Kagan and Neil Gorsuch.[3]

    The court upheld a decision from a majority of circuit courts, holding the statute of limitations for a Section 1983 claim based on fabrication of evidence in criminal proceedings begins to run when those proceedings terminate in the defendant's favor.[3]

    Opinion

    In her opinion, Justice Sotomayor wrote:[3]

    “ The statute of limitations for a fabricated-evidence claim like McDonough’s does not begin to run until the criminal proceedings against the defendant (i.e., the §1983 plaintiff) have terminated in his favor. This conclusion follows both from the rule for the most natural common-law analogy (the tort of malicious prosecution) and from the practical considerations that have previously led this Court to defer accrual of claims that would otherwise constitute an untenable collateral attack on a criminal judgment. ...


    The soundness of this conclusion is reinforced by the consequences that would follow from the Second Circuit’s approach, which would impose a ticking limitations clock on criminal defendants as soon as they become aware that fabricated evidence has been used against them. Such a rule would create practical problems in jurisdictions where prosecutions regularly last nearly as long as—or even longer than—the relevant civil limitations period. [9]

    		”

    Dissenting opinion

    Justice Thomas filed a dissenting opinion, joined by Justices Kagan and Gorsuch.

    In his dissent, Justice Thomas wrote that the court should have dismissed the case as improvidently granted.[3] Dismissed as improvidently granted, often referred to as DIG, occurs when the court chooses not to decide a case, even after accepting the appeal or hearing the arguments.[10]

    Thomas wrote that McDonough did not identify the specific constitutional right at issue and that this failure "profoundly complicates our inquiry."[3]

    “ Because the constitutional basis for McDonough’s claim is unclear, we are unable to confirm that he has a constitutional claim at all. In my view, it would be both logical and prudent to address that antecedent question before addressing the statute of limitations for that claim.[9] ”

    Text of the opinion

    Read the full opinion here.

    Audio


    Transcript

    See also

    External links

    Footnotes

    1. ↑ SCOTUSblog, "McDonough v. Smith," accessed March 26, 2019
    2. ↑ 2.0 2.1 Supreme Court of the United States, "McDonough v. Smith: Questions presented," accessed March 26, 2019
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 Supreme Court of the United States, McDonough v. Smith, decided June 20, 2019
    4. ↑ 4.0 4.1 4.2 4.3 4.4 U.S. Court of Appeals for the 2nd Circuit, McDonough v. Smith, August 3, 2018
    5. ↑ 5.0 5.1 5.2 5.3 Oyez, "McDonough v. Smith: Facts of the case," accessed March 26, 2019
    6. ↑ SCOTUSblog, "Eight new grants, Ginsburg recovery from surgery 'on track,'" January 11, 2019
    7. ↑ 7.0 7.1 7.2 United States District Court for the Northern District of New York, McDonough v. Smith, September 30, 2016
    8. ↑ NOLO, "What Is a "Section 1983" Lawsuit Against the Police?" accessed March 28, 2019
    9. ↑ 9.0 9.1 9.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    10. ↑ Porter Wright, "Can you 'DIG' it? The dismissal of appeals as improvidently granted," accessed April 23, 2019
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