Jerome Raheem Simpson v. State of Florida
708 F. App'x 635
| 11th Cir. | 2018Background
- Simpson, a pro se prisoner, signed and had a § 1983 complaint stamped as received by prison officials on September 23, 2016.
- He alleged jail officials lost or disposed of his personal property after he was transferred; he says property was exposed to disposal on August 21, 2012 and disposed of on September 24, 2012.
- District court sua sponte dismissed the complaint as time-barred under Florida’s four-year statute of limitations, treating the accrual date as August 21, 2012.
- Simpson argued the claim accrued when the property was finally disposed of (September 24, 2012) and that his pro se filing date is the date he delivered the complaint to prison officials (September 23, 2016).
- The Eleventh Circuit reviewed de novo whether the complaint accrued and whether the filing was timely under the state limitations period.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did Simpson's § 1983 property-deprivation claim accrue? | Accrual occurred when prison finally disposed of the property (Sept. 24, 2012). | Accrual occurred earlier (Aug. 21, 2012) when property was first exposed to disposal during transfer. | Claim accrued on disposal date (Sept. 24, 2012). |
| Was Simpson's complaint timely under Florida's four-year statute of limitations? | Complaint was delivered/stamped Sept. 23, 2016, within four years of Sept. 24, 2012 (timely). | Complaint was filed after the four-year period expired if accrual was earlier. | Complaint was timely; district court erred in dismissal. |
| Is a district court permitted to sua sponte dismiss a § 1983 complaint as time-barred at screening? | N/A (procedural) | N/A (procedural) | Yes, a court may dismiss sua sponte if the claim is barred by the statute of limitations. |
| What is the proper filing date for a pro se prisoner’s § 1983 complaint? | Filing date = date delivered to prison officials (signature/stamp). | N/A | Filing date is date of delivery to prison officials (Garvey/Houston rule). |
Key Cases Cited
- Hughes v. Lott, 350 F.3d 1157 (11th Cir. 2003) (standard for reviewing a dismissal for failure to state a claim)
- Foudy v. Indian River Cty. Sheriff’s Office, 845 F.3d 1117 (11th Cir. 2017) (de novo review of statute-of-limitations interpretation)
- Jones v. Bock, 549 U.S. 199 (2007) (courts may dismiss sua sponte where action is barred by statute of limitations)
- Chappell v. Rich, 340 F.3d 1279 (11th Cir. 2003) (Florida’s four-year limitations period for § 1983 claims)
- Wallace v. Kato, 549 U.S. 384 (2007) (accrual occurs when plaintiff has a complete and present cause of action)
- Corn v. City of Lauderdale Lakes, 904 F.2d 585 (11th Cir. 1990) (property-deprivation claims accrue upon a final decision on the fate of the property)
- Garvey v. Vaughn, 993 F.2d 776 (11th Cir. 1993) (pro se prisoner filing date is date of delivery to prison officials)
- Houston v. Lack, 487 U.S. 266 (1988) (mailbox rule for filing by pro se prisoners)