654 F. App'x 781
6th Cir.2016Background
- In December 2012, teacher Chavonne Printup restrained a disruptive student at St. Aloysius; the student later had bruises and Printup had a bite wound.
- Butler County Children’s Services social workers designated Printup an “indicated” child-abuse perpetrator and placed her on Ohio’s Central Registry; St. Aloysius then terminated her employment.
- Printup received an administrative hearing; the hearing officer (BCCSB ombudsman) affirmed the designation on February 11, 2013.
- Printup appealed; the state court reversed the administrative decision on January 27, 2014, finding procedural and legal errors, and the BCCSB did not appeal.
- On February 10, 2015 Printup filed a 42 U.S.C. § 1983 suit against Butler County alleging Monell claims for failure to train social workers and the hearing officer, asserting procedural and substantive due-process violations. The district court dismissed with prejudice as time-barred under Ohio’s two-year statute of limitations; Printup appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did Printup’s § 1983 claims accrue for statute-of-limitations purposes? | Accrual occurred when the administrative hearing officer issued his Feb. 11, 2013 decision (first time she knew County caused constitutional injury). | Accrual occurred earlier — when social workers placed her on the Central Registry and she lost her job (events >2 years before suit). | Claims accrued when Printup was designated and lost her job; suit filed after two-year limit and is time-barred. |
| Does the stigma-plus theory mean the cause of action accrues only after the ‘‘plus’’ is finalized by a later process? | The constitutional tort is not complete until the tangible burden (plus) is imposed or until the later hearing confirmed deprivation. | The stigma-plus injury occurred upon designation and job loss; subsequent affirmation not required to complete injury. | The court held the injury occurred when she was placed on the Registry and terminated; subsequent hearing affirmation did not delay accrual. |
| Does the continuing-violation doctrine delay accrual until the hearing officer’s decision? | Butler County’s failure to train was ongoing; the hearing officer’s decision was part of a continuing wrongful course so accrual should be delayed. | The Registry listing and termination were discrete wrongful acts; ongoing ill effects do not create a continuing violation. | Doctrine does not apply; the hearing officer’s decision was not a continuing wrongful act that tolled the limitations period. |
| Is Heck v. Humphrey applicable such that accrual is deferred until the state court invalidated the administrative decision? | Heck’s accrual-deferral logic should apply; her claims depended on the state court reversal (Jan. 27, 2014). | Heck applies only to outstanding criminal convictions/sentences and not to this administrative context after Wallace. | Heck inapplicable; accrual not deferred to state-court reversal date. |
Key Cases Cited
- Banks v. City of Whitehall, 344 F.3d 550 (6th Cir.) (statute-of-limitations review de novo for § 1983 accrual)
- Wilson v. Garcia, 471 U.S. 261 (U.S. 1985) (state personal-injury limitations period governs § 1983).
- Wallace v. Kato, 549 U.S. 384 (U.S. 2007) (federal law governs accrual; Heck limited to outstanding criminal judgments).
- Browning v. Pendleton, 869 F.2d 989 (6th Cir.) (Ohio two-year limitations governs bodily-injury § 1983 claims).
- Mitchell v. Fankhauser, 375 F.3d 477 (6th Cir.) (Parratt–Vicory–Jefferson line applies to random/unauthorized deprivations; established procedures differ).
- Eidson v. State of Tenn. Dep’t of Children’s Servs., 510 F.3d 631 (6th Cir.) (substantive-due-process conscience-shocking standard; continuing-violation limits).
- Monell v. Dep’t of Social Servs., 436 U.S. 658 (U.S. 1978) (municipal liability requires policy/custom).
- Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (accrual deferred only where conviction/sentence remains outstanding).