56 F.4th 50
D.C. Cir.2022Background
- Jabari Stafford, a Black student and GWU men’s tennis player, alleges sustained racial harassment by teammates and participation by the head coach, leading to academic decline and suspension; he never returned to GWU.
- Stafford filed a Title VI claim (racial discrimination by a federal-funds recipient) in November 2018; the district court denied GWU’s motion to dismiss and the case proceeded to discovery.
- GWU moved for summary judgment, arguing Stafford’s claim was time‑barred by the D.C. Human Rights Act’s one‑year limitations period (DCHRA § 2-1403.16).
- The district court granted summary judgment applying the DCHRA one‑year period but noted that under the three‑year residual personal‑injury period (D.C. Code § 12‑301(8)) a factual dispute would preclude summary judgment.
- On appeal Stafford argued the three‑year residual limitations period applies to Title VI claims in D.C.; the D.C. Circuit reversed, holding the three‑year residual period governs and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Appropriate limitations period for Title VI claims in D.C. | Use D.C.’s three‑year residual personal‑injury period (§ 12‑301(8)). | Use the DCHRA’s one‑year limitations period (§ 2‑1403.16). | Three‑year residual personal‑injury period applies; Title VI is most analogous to personal‑injury claims under Wilson/Goodman/Owens. |
| Alternative: grant summary judgment under three‑year period | N/A (argued only that three years applies so claim survives). | Even under three years, summary judgment should be affirmed. | Reversed district court’s judgment; genuine factual dispute exists so summary judgment inappropriate on limitations ground. |
Key Cases Cited
- Wilson v. Garcia, 471 U.S. 261 (1985) (federal civil‑rights claims are most analogous to personal‑injury actions for limitations‑borrowing).
- Goodman v. Lukens Steel Co., 482 U.S. 656 (1987) (characterizes discrimination as a personal injury supporting personal‑injury limitations).
- Owens v. Okure, 488 U.S. 235 (1989) (apply state residual personal‑injury statute where no general personal‑injury statute exists).
- DelCostello v. International Brotherhood of Teamsters, 462 U.S. 151 (1983) (do not presume Congress intended no limitations; borrow appropriate state limitation).
- Agency Holding Corp. v. Malley‑Duff & Associates, Inc., 483 U.S. 143 (1987) (endorses borrowing state limitations for federal causes when Congress is silent).
- Regents of the Univ. of California v. Bakke, 438 U.S. 265 (1978) (describes Title VI as a prohibition on racial discrimination by federal‑fund recipients, analogous to constitutional protections).
- Rozar v. Mullis, 85 F.3d 556 (11th Cir. 1996) (supports uniformity by treating civil‑rights statutes like personal‑injury claims for limitations purposes).
- Monroe v. Columbia College Chicago, 990 F.3d 1098 (7th Cir. 2021) (applies three‑year residual period to Title VI claims).
- Jaiyeola v. District of Columbia, 40 A.3d 356 (D.C. 2012) (D.C. Court of Appeals applied DCHRA one‑year period to Rehabilitation Act claim; court of appeals here rejected its approach).