United States v. Edgar Searcy, 880 F.3d 116

Edgar Joe Searcy was federally convicted under 18 U.S.C. § 2422(b), sentenced to 180 months, with scheduled prison release June 25, 2016.
As Searcy neared release, the Bureau of Prisons certified him under the Adam Walsh Act (18 U.S.C. § 4248) as a "sexually dangerous person" and petitioned for civil commitment in December 2015.
Searcy did not contest the factual findings; he moved to dismiss arguing the government’s certification was time-barred by the four-year catch-all statute of limitations, 28 U.S.C. § 1658(a), which he said should run from the Adam Walsh Act’s enactment.
The district court denied dismissal, held § 1658(a) does not apply to § 4248 proceedings, conducted a hearing with psychiatric testimony, and committed Searcy to the Attorney General’s custody as sexually dangerous.
On appeal the Fourth Circuit reviewed de novo whether § 1658(a) applies to Adam Walsh civil commitment proceedings and affirmed the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 28 U.S.C. § 1658(a)’s 4‑year catch‑all statute of limitations applies to civil commitment proceedings under the Adam Walsh Act (18 U.S.C. § 4248).	Searcy: § 1658(a) supplies a 4‑year deadline (running from the Act’s enactment) and the government filed certification too late.	Gov: § 1658(a) is displaced because § 4248 itself prescribes timing (proceedings may only be initiated while person is in federal custody) and § 4248 is not the kind of "civil action" § 1658 targets.	The Fourth Circuit held § 1658(a) does not apply: § 4248’s custody‑based timing effectively supplies the applicable timing rule and civil commitment is not the sort of "civil action" § 1658 was intended to cover.

Kansas v. Hendricks, 521 U.S. 346 (1997) (prior violent behavior relevant to predicting future dangerousness; civil commitment can be nonpunitive)
Addington v. Texas, 441 U.S. 418 (1979) (civil commitment is civil, not criminal; heightened due process protections)
United States v. Comstock, 560 U.S. 126 (2010) (federal civil commitment as part of responsible prison administration)
Jones v. R.R. Donnelley & Sons, 541 U.S. 369 (2004) (background on limitations‑borrowing problems that § 1658 sought to cure)
North Star Street Co. v. Thomas, 515 U.S. 29 (1995) (§ 1658 supplies a 4‑year limitation for federal statutes enacted without one)
United States v. Perez, 752 F.3d 398 (4th Cir. 2014) (§ 4248’s procedures can displace ordinary Federal Rules of Civil Procedure)