J. M. v. Or. Youth Auth., 434 P.3d 402

In 1998 plaintiff (age 15) was sexually abused repeatedly by OYA employee Milligan at an OYA facility where Lawhead was superintendent; plaintiff did not report the abuse at the time.
Plaintiff repressed the abuse until 2012, when media coverage prompted recall and investigation; by 2012 he discovered arrests/convictions of Milligan and later information suggesting Lawhead played a role in enabling the abuse.
In May 2014 plaintiff sued Lawhead under 42 U.S.C. § 1983 alleging Eighth and Fourteenth Amendment violations based on deliberate indifference to a known risk of sexual abuse.
Lawhead moved for summary judgment, arguing the § 1983 claim was time-barred by Oregon’s two-year tort statute of limitations because, under federal accrual law, the claim accrued when the abuse occurred in 1998.
The trial court granted summary judgment; the Oregon Court of Appeals reversed relying on T. R. v. Boy Scouts (Oregon Supreme Court precedent adopting a discovery accrual rule). The Oregon Supreme Court granted review to decide the federal accrual rule for § 1983 claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does a § 1983 cause of action accrue for statute-of-limitations purposes?	J.M.: Accrual follows a discovery rule — limitations run only once a reasonably prudent plaintiff knows (or should know) both the injury and the defendant’s role.	Lawhead: Post-Wallace accrual is occurrence-based or, at most, requires discovery of the injury alone; plaintiff’s claim accrued in 1998.	The court held accrual occurs when the plaintiff knows or reasonably should know of the injury AND the defendant’s causal role; T.R. reaffirmed.

Wallace v. Kato, 549 U.S. 384 (2007) (accrual is a federal question guided by common-law tort principles and occurs when plaintiff has a complete and present cause of action)
Manuel v. City of Joliet, 137 S. Ct. 911 (2017) (reaffirmed using common-law principles to define accrual and emphasized flexibility and attention to constitutional right’s purposes)
T. R. v. Boy Scouts of Am., 344 Or. 282 (2008) (Oregon precedent adopting a discovery accrual rule requiring knowledge of both injury and defendant’s role)
Bay Area Laundry & Dry Cleaning Pension Trust Fund v. Ferbar Corp., 522 U.S. 192 (1997) (distinguishes statutory discovery tolling provisions from the ‘‘standard rule’’ that limitations begins when a cause of action is complete)
Gabelli v. SEC, 568 U.S. 442 (2013) (declined to apply a discovery rule to government enforcement actions; not dispositive for private § 1983 claims)
Piotrowski v. City of Houston, 237 F.3d 567 (5th Cir. 2001) (articulates accrual requiring awareness of injury and causation; used by several circuits to support a discovery-of-causation rule)