Derrick Newman v. James Guedry, 464 F. App'x 359

Newman was detained by Beaumont Police Department officers on August 24, 2007, during a traffic stop related to an outstanding warrant for Mario Cole.
Newman sued multiple defendants, but on appeal only §1983 claims against Coffin (Chief of Police), Hayes (City Manager), and the City of Beaumont survive, with others dismissed.
The district court held Newman’s §1983 claim against the municipal defendants was time-barred by the statute of limitations.
Texas two-year statute of limitations governs §1983 actions, beginning when the plaintiff learns of injury and its cause, applying federal accrual rules but state-law period.
Newman learned of the zero-tolerance policy during or after an internal investigation and discovery process in 2010–2011, after which he amended his complaint.
The district court dismissed the municipal defendants’ claims on May 4, 2011, and the court of appeals affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When did the §1983 claim accrue?	Newman contends accrual requires learning injury and its cause; he only learned the policy’s existence at Schuldt’s trial.	Defendants argue accrual occurs when the plaintiff learns of injury and facts leading to causation, triggering a duty to investigate.	Accrual occurred at the arrest; duty to investigate should have led to discovery of the policy.
Did Newman have a duty to investigate upon arrest, triggering earlier accrual?	Newman asserts no knowledge of the policy at arrest, so accrual should be later.	Newman had a duty to exercise due diligence based on available information at arrest.	Yes, duty to investigate arose at arrest, which would have revealed the zero-tolerance policy.
Is the claim time-barred under Texas two-year statute of limitations given accrual date?	The claim accrued later, so within two years of discovery.	Two-year period began at accrual date (arrest), barring timely filing.	Yes, the action was time-barred.

Piotrowski v. City of Hous., 51 F.3d 512 (5th Cir. 1995) (accrual triggers when plaintiff knows or should know the injury and causation; governing law for accrual in §1983 actions)
Piotrowski v. City of Hous. (Piotrowski II), 237 F.3d 567 (5th Cir. 2001) (continued accrual principles; knowledge or notice sufficient to trigger diligence period)
Jensen v. Snellings, 841 F.2d 600 (5th Cir. 1988) (duty to investigate facts underlying injury; knowledge not controlling for accrual)
Sumner v. Land & Leisure, Inc., 664 F.2d 965 (5th Cir. 1981) (due diligence standard in determining accrual; factual inquiry depends on circumstances)
Jones v. Alcoa, Inc., 339 F.3d 359 (5th Cir. 2003) (due diligence inquiry governs accrual timing; factual questions on diligence)