Sykes v. US ATTORNEY FOR THE DIST. OF COLUMBIA
770 F. Supp. 2d 152
D.D.C.2011Background
- Plaintiff Sykes was convicted in 1997 of armed robbery and related offenses.
- In 2006, the D.C. Court of Appeals reversed the convictions for Brady material violations and released him.
- On June 5, 2010, Sykes filed a federal civil suit against federal and D.C. defendants asserting Brady-related and other constitutional claims.
- Defendants moved to dismiss arguing the claims are time-barred under DC and federal limitations principles.
- The court analyzes DC statute of limitations, accrual, and tolling to determine timeliness.
- The court concludes all claims are time-barred and grants dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the claims are time-barred under DC law | Sykes contends a timely filing date; discovery rule tolled accrual. | Claims accrued at release in 2006 and were not filed within three years. | Claims are time-barred |
| What statute of limitations governs Bivens/§1983 and related claims | Residual three-year period applies to Bivens/§1983 claims. | General limitations apply and are shorter for certain torts. | Three-year residual period governs |
| When accrual occurred for the claimed injuries | Discovery rule delays accrual until discovery of wrongdoing. | Accrual occurred at release in 2006 upon knowledge of injury and wrongdoing. | Accrual in 2006; filing in 2010 barred |
| Impact of imprisonment on accrual and tolling | Tolling during imprisonment extends time to sue. | Tolling applies but accrual occurred by 2006, shortening window. | Tolling does not save timely filing; accrual occurred while imprisoned and after release |
Key Cases Cited
- Mullin v. Washington Free Weekly, Inc., 785 A.2d 296 (D.C.2001) (one-year defamation statute of limitations)
- Rochon v. FBI, 691 F.Supp. 1548 (D.D.C.1988) (three-year limitations for negligence and related claims)
- Prouty v. National R. Passenger Corp., 572 F.Supp. 200 (D.D.C.1983) (three-year limitations for negligence claims)
- Rendall-Speranza v. Nassim, 107 F.3d 913 (D.C.Cir.1997) (intentional infliction of emotional distress three-year period)
- Doe v. Southeastern University, 732 F.Supp. 7 (D.D.C.1990) (intertwined torts; distress claims follow underlying torts' period)
- Carney v. American Univ., 151 F.3d 1090 (D.C.Cir.1998) (§1983 claims governed by residual limitations per Owens v. Okure)
- Owens v. Okure, 488 U.S. 235 (1989) (establishes general residual limitations for multiple statutes)
- Smith-Haynie v. District of Columbia, 155 F.3d 575 (D.C.Cir.1998) (rule on when 12(b)(6) dismissal based on statute of limitations is proper)
- Doe v. Dep't of Justice, 753 F.2d 1092 (D.C.Cir.1985) (federal claims borrow state limitations when none provided)
- Hagmeyer v. Dep't of Treasury, 647 F.Supp. 1300 (D.D.C.1986) (recognizes three-year period for Bivens-like actions)