John Jones v. City of Franklin
677 F. App'x 279
6th Cir.2017Background
- John Jones alleges police transported him to Williamson Medical Center on August 21, 2013; there he was forced to provide blood/urine and subjected to a catheterization he challenges under § 1983 and Tennessee law.
- Jones filed suit on August 22, 2014 — one day beyond Tennessee’s one-year statute of limitations for personal-injury/federal-rights claims.
- Jones argues the limitations period was tolled because he was "adjudicated incompetent" (or otherwise incompetent) upon admission, so the statute began to run after his rights were "restored," making his filing timely.
- Defendants moved for summary judgment (and judgment on the pleadings for one defendant), asserting the suit is time-barred because the cause of action accrued on August 21, 2013 and no judicial adjudication of incompetence occurred.
- The district court found (1) the cause of action accrued on August 21, 2013, (2) Jones was not "adjudicated incompetent" at that time, and (3) Tennessee’s tolling provision requires a judicial determination of incompetency to toll the limitations period; it granted judgment for defendants and declined to certify the question to the Tennessee Supreme Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did the § 1983 statute of limitations accrue? | Jones: factual dispute about accrual date; argues tolling to Aug 22, 2013 | Defendants: accrual was Aug 21, 2013 (records, plaintiff’s concessions) | Accrual: Aug 21, 2013 — plaintiff knew or had reason to know on that date; filing was one day late |
| Does Tenn. Code Ann. § 28-1-106 toll the statute when a plaintiff is found mentally incompetent by medical staff (but not judicially)? | Jones: statute should toll when plaintiff is incapacitated/unable to protect rights (functional test) | Defendants: statute requires a judicial adjudication of incompetency to toll | Held: statute’s phrase "adjudicated incompetent" requires a judicial determination; medical findings alone do not toll |
| Did the 2011 amendment change the standard from functional "unsound mind" to requiring judicial action? | Jones: amendment was non-substantive, merely modernized language; original "unsound mind" test remains | Defendants: amendment’s wording and surrounding language show deliberate shift to require judicial adjudication and restoration of legal rights | Held: the text (and noscitur a sociis) indicates the legislature intended adjudication and restoration of legal rights — i.e., judicial action |
| Should the court certify to the Tennessee Supreme Court whether a judicial determination is required? | Jones: question unsettled; certification appropriate | Court/Defendants: existing federal and Tennessee appellate decisions address the issue | Held: Court declined certification — question not sufficiently unsettled given controlling textual/precedential authorities |
Key Cases Cited
- Roberson v. Tennessee, 399 F.3d 792 (6th Cir.) (statute of limitations for § 1983 claims drawn from state law; accrual is when plaintiff knows or should know of injury)
- Hardin v. Staub, 490 U.S. 536 (1989) (state tolling rules may apply to § 1983 claims unless inconsistent with federal policy)
- Sherrill v. Souder, 325 S.W.3d 584 (Tenn. 2010) (ability-to-manage-day-to-day-affairs test discussed under prior statutory language)
- Bd. of Regents v. Tomanio, 446 U.S. 478 (1980) (discussing application of state tolling rules to federal claims)
- Baldwin County Welcome Center v. Brown, 466 U.S. 147 (1984) (procedural limitations must be enforced even if outcome seems harsh)