575 F. App'x 865
11th Cir.2014Background
- Earl Meggison Sr., who pled guilty in 1990 to molesting his step-daughter, was notified by the Florida Department of Law Enforcement (FDLE) on October 27, 2005, that he must register under Florida’s 1997 sex-offender statute, Fla. Stat. § 943.0435.
- Meggison filed a § 1983 suit in federal court on May 20, 2013, claiming enforcement of the registration requirement violated his substantive due process rights.
- The district court dismissed the complaint as time-barred under Florida’s four-year statute of limitations applicable to § 1983 claims.
- Meggison argued on appeal that (1) the accrual date was later because state-court proceedings (including a stay) postponed accrual, and (2) the continuing-violation doctrine made his claim timely.
- The Eleventh Circuit reviewed the dismissal de novo and rejected both arguments, affirming dismissal as untimely.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did the § 1983 claim accrue for statute-of-limitations purposes? | Accrual was postponed by subsequent state-court proceedings and a stay; cause of action became complete when the stay was lifted. | Accrual occurred when FDLE first required Meggison to register (Oct. 27, 2005); later state proceedings did not change accrual. | Accrual occurred when FDLE first required registration; suit filed in 2013 is time-barred. |
| Does the continuing-violation doctrine save the claim? | The ongoing effects of the registration requirement create a continuing violation, extending the limitations period. | The classification/registration was a discrete one-time act with continuing consequences; continuing-violation doctrine does not apply. | No; the act was discrete with continuing effects, so the continuing-violation doctrine does not extend the limitations period. |
Key Cases Cited
- Wallace v. Kato, 549 U.S. 384 (establishes accrual occurs when plaintiff has a complete and present cause of action)
- Chappell v. Rich, 340 F.3d 1279 (Florida’s four-year statute of limitations applies to § 1983 claims)
- Doe v. Moore, 410 F.3d 1337 (substantive due-process claims by Florida residents required to register as sex offenders)
- Brown v. Ga. Bd. of Pardons & Paroles, 335 F.3d 1259 (limitations period begins when facts supporting claim are apparent to a reasonably prudent person)
- Lovett v. Ray, 327 F.3d 1181 (one-time act with continued consequences does not trigger continuing-violation tolling)
- Knight v. Columbus, Ga., 19 F.3d 579 (distinguishes continuing violations from discrete past violations with lingering effects)
- Glover v. Liggett Grp., Inc., 459 F.3d 1304 (standard of de novo review for Rule 12(b)(6) dismissals)