990 F.3d 1098
7th Cir.2021Background
- Vaun Monroe was denied tenure at Columbia College Chicago and sued, asserting among other claims a Title VI race-discrimination claim (Count IV).
- Title VI contains no limitations period; federal courts borrow the most analogous state limitations period for actions under pre-1990 federal statutes.
- The central question was whether Illinois’s five-year catchall civil limitations period (735 ILCS 5/13-205) or its two-year personal-injury period (735 ILCS 5/13-202) governs Title VI claims.
- The district court held the two-year personal-injury period applied and granted summary judgment as Monroe’s Title VI claim was filed after two years.
- On appeal the Seventh Circuit considered circuit precedent and other circuits’ decisions treating Title VI as analogous to §1981/§1983 and adopted the two-year personal-injury limitations period, affirming dismissal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Which Illinois statute of limitations governs Title VI claims? | Monroe argued Beard v. Robinson supports applying Illinois’s five-year catchall limitations period. | Columbia College argued Title VI claims are analogous to §1981/§1983 and thus borrow Illinois’s two-year personal-injury period. | The court held Title VI is analogous to §1981/§1983 and applied Illinois’s two-year personal-injury statute; Monroe’s claim was untimely. |
| Is Beard controlling so Title VI gets a five-year period? | Monroe relied on Beard’s broad statement that the Illinois five-year period applies to Civil Rights Act claims. | College pointed out Beard predated Supreme Court decisions requiring personal-injury periods for §1981/§1983 and that Beard did not address Title VI. | The court rejected Beard as controlling for Title VI in light of Wilson/Owens/Goodman and treated Beard as distinguishable. |
Key Cases Cited
- Bd. of Regents of Univ. of State of N.Y. v. Tomanio, 446 U.S. 478 (adopting state limitation periods when federal statute is silent)
- Wilson v. Garcia, 471 U.S. 261 (federal courts borrow state personal-injury limitations for §1983 claims)
- Owens v. Okure, 488 U.S. 235 (affirming Wilson rule on limitations for §1983)
- Goodman v. Lukens Steel Co., 482 U.S. 656 (applying state personal-injury limitations to §1981 claims)
- Baker v. Bd. of Regents of State of Kansas, 991 F.2d 628 (10th Cir.) (Title VI analogous to §1981/§1983; borrow personal-injury period)
- Jersey Heights Neighborhood Ass’n v. Glendening, 174 F.3d 180 (4th Cir.) (Title VI governed by state personal-injury period)
- Rozar v. Mullis, 85 F.3d 556 (11th Cir.) (same)
- Egerdahl v. Hibbing Cmty. Coll., 72 F.3d 615 (8th Cir.) (same)
- Taylor v. Regents of Univ. of Cal., 993 F.2d 710 (9th Cir.) (same)
- Sewell v. Monroe City Sch. Bd., 974 F.3d 577 (5th Cir.) (same)
- Beard v. Robinson, 563 F.2d 331 (7th Cir.) (earlier decision applying Illinois five-year period to civil-rights claims; distinguished)
- Bush v. Commonwealth Edison Co., 990 F.2d 928 (7th Cir.) (applied Illinois two-year period to Rehabilitation Act claim)
- Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (context for Beard’s subject matter)