Dwight Davis v. John Noble
682 F. App'x 142
| 3rd Cir. | 2017Background
- Davis sued under 42 U.S.C. § 1983 more than a decade after Delaware Chancery Court litigation in which the Chancery Court declared him a proper board member (partial summary judgment 2002; final judgment 2003).
- He alleged (sparsely) that the Committee went inactive after the 2003 order, reconstituted in 2004 with a different board, and that by 2011 he learned the reorganized group had misused funds.
- Davis sought a federal writ of mandamus compelling the Delaware court to enforce its 2002–2003 orders and to enter a final judgment entitled to full faith and credit; he also sought damages for the Delaware court’s alleged failure to act.
- Defendants moved to dismiss; the District Court granted dismissal (Aug. 24, 2016), concluding § 1983 claims were time-barred under the two-year Delaware rule, and noting judicial immunity and lack of state-action for some defendants; the court declined to issue mandamus to a state court and declined supplemental jurisdiction over any state-law claims.
- The District Court denied reconsideration and disqualification; Davis appealed. The Third Circuit affirmed, largely adopting the District Court’s reasoning.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Statute of limitations for § 1983 claims | § 1983 has no federal statute of limitations; alternatively tolling/fraudulent concealment applies | § 1983 claims are governed by a two-year limitations period; Davis pleaded facts showing he knew of injury by 2011, so suit filed too late | Claims time-barred; District Court properly applied two-year Delaware limitations and dismissal was appropriate |
| Federal mandamus directing state court | Federal court can issue writ to compel Delaware court to enforce its orders | Federal courts lack jurisdiction to issue mandamus to state courts | No jurisdiction to issue mandamus to a state court; dismissal of that relief affirmed |
| Supplemental/original jurisdiction to enforce state-court orders | District Court should have exercised original jurisdiction or cited more authority | District Court acted within discretion to decline supplemental jurisdiction under 28 U.S.C. § 1367(c) | Declining to exercise supplemental jurisdiction was proper and discretionary |
| Allegation that District Court merely adopted defendants’ pleadings | District Court improperly adopted defendants’ briefs verbatim | District Court issued its own opinion and independently analyzed issues | No error; District Court did not simply adopt defendants’ filings verbatim |
Key Cases Cited
- McDowell v. Delaware State Police, 88 F.3d 188 (3d Cir.) (statute of limitations for § 1983 claims governed by state limitations period)
- Stephens v. Clash, 796 F.3d 281 (3d Cir. 2015) (statute-of-limitations defense may be apparent on the face of the complaint)
- In re Wolenski, 324 F.2d 309 (3d Cir. 1963) (federal courts lack jurisdiction to issue a writ of mandamus to compel a state court)
- In re Grand Jury Proceedings (Wright II), 654 F.2d 268 (3d Cir. 1981) (federal courts ordinarily may not issue mandamus to control state courts)
- De Asencio v. Tyson Foods, Inc., 342 F.3d 301 (3d Cir. 2003) (factors and discretion underlying dismissal of supplemental jurisdiction)
- Burtch v. Milberg Factors, Inc., 662 F.3d 212 (3d Cir. 2011) (standards of review: Rule 12(b)(6) de novo review; denial of leave to amend/reconsider reviewed for abuse of discretion)