PETERSON v. CAMDEN COUNTY CORRECTIONAL FACILITY, 1:16-cv-09141

Plaintiff Winston J. Peterson, proceeding pro se and in forma pauperis, sued Camden County Correctional Facility under 42 U.S.C. § 1983 alleging unconstitutional conditions of confinement (overcrowding, sleeping on the floor, illnesses/injuries).
Alleged incidents occurred on October 10, 2002; April 18, 2006; July 27, 2007; September 16, 2007; and December 7, 2010.
Court conducted sua sponte screening under 28 U.S.C. § 1915(e)(2) to determine whether the complaint must be dismissed as frivolous, malicious, for failure to state a claim, or for seeking relief from an immune defendant.
The governing limitations rule: § 1983 claims borrow the New Jersey personal-injury two-year statute of limitations; claims accrue when plaintiff knew or should have known of the injury.
The court determined the alleged conditions were contemporaneously discoverable, so accrual occurred no later than the detention dates; the limitations period expired by December 7, 2012 at the latest.
Court declined equitable tolling, finding no active state concealment, no extraordinary circumstances, and no filing in the wrong forum; dismissed the complaint with prejudice for failure to state a claim as time-barred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Peterson's § 1983 conditions-of-confinement claims are time‑barred	Peterson alleges unconstitutional conditions on specified detention dates and seeks relief	CCCF argues the claims accrued at the time of detention and are barred by New Jersey's two‑year statute	Court held claims accrued when discoverable and are barred because suit filed in 2016, beyond two‑year limit (dismissed with prejudice)
Whether tolling applies to revive untimely claims	Peterson implicitly seeks relief despite delay (no tolling facts pleaded)	CCCF/no party argues no basis for tolling: no active concealment or extraordinary circumstances	Court held equitable tolling not warranted on the complaint’s face; dismissal stands

Wilson v. Garcia, 471 U.S. 261 (determination of applicable statute of limitations for § 1983 claims)
Dique v. New Jersey State Police, 603 F.3d 181 (two‑year limitations period applies to § 1983 claims in New Jersey)
Montanez v. Secretary Pa. Dep't of Corr., 773 F.3d 472 (accrual when plaintiff knew or should have known of injury)
Kach v. Hose, 589 F.3d 626 (same accrual principle)
Fowler v. UPMS Shadyside, 578 F.3d 203 ( pleading standard for plausibility under § 1915 screening)
Fair Wind Sailing, Inc. v. Dempster, 764 F.3d 303 (discussion of facial plausibility standard)
Ashcroft v. Iqbal, 556 U.S. 662 (labels-and-conclusions insufficient for plausibility)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (pleading standards requiring more than formulaic recitation)