Wilson v. Illinois Department of Financial & Professional Regulation
2017 U.S. App. LEXIS 17289
| 7th Cir. | 2017Background
- In Sept. 1998 Dr. Robert Wilson injected a terminally ill patient to palliate suffering; the patient’s heart stopped and the coroner initially labeled the death a homicide. The Illinois Department of Financial and Professional Regulation summarily suspended Wilson’s medical license without a hearing.
- Wilson sought administrative review and filed federal §1983 litigation in 1999; the district court dismissed under Younger abstention while state proceedings were ongoing.
- State courts repeatedly set aside the Department’s suspension decisions for procedural defects; the Department repeatedly reimposed five‑year suspensions without credit for time already served. In May 2014 the Circuit Court conclusively held the evidence did not support any suspension and Wilson should not have been suspended.
- The Department nonetheless refused to restore Wilson to practice, later demanding he complete a 3‑year graduate medical program before requalification, effectively treating him as having lost his medical credentials.
- Wilson filed a §1983 damages suit in federal court in late 2014/2016; the district court held his §1983 claim was time‑barred because the two‑year statute of limitations began in 1998 when the summary suspension occurred.
- On appeal, the Seventh Circuit held Wilson’s §1983 claim did not accrue while state administrative and judicial proceedings were pending and that his claim accrued only when the state litigation ended in May 2014, making his federal suit timely.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Heck v. Humphrey bars §1983 damages for state professional discipline until state proceedings are invalidated | Heck should be extended to professional disciplinary proceedings; Wilson need not await state invalidation | Heck precludes federal suit until state invalidation | Court: Heck does not apply—Heck’s custody/rule rationale does not extend to noncustodial administrative discipline |
| When a §1983 claim accrues (statute of limitations) after administrative and state court review | Accrual deferred until state proceedings concluded (May 2014); suit timely | Accrual began at summary suspension in 1998; suit time‑barred | Court: Under Wallace accrual rule, claim did not accrue until state litigation ended in May 2014; statute did not run earlier |
| Effect of Younger abstention and prior district dismissal on timing of accrual | Younger stay/dismissal prevented federal damages suit while state proceedings pending; accrual deferred | Statute ran irrespective of Younger; dismissal traps plaintiff | Court: Younger barred federal adjudication while state process pending; combined with accrual rule, plaintiff’s claim was incomplete until state proceedings ended |
| Whether defendants can invoke statute of limitations given requested dismissal (versus stay) of first federal suit (equitable estoppel) | Defendants’ earlier request to dismiss (instead of stay) should not enable limitation defense now | Defendants may plead limitations despite prior dismissal request | Court: Declined to decide estoppel; resolved appeal on accrual rule so limitations defense rejected because claim accrued in 2014 |
Key Cases Cited
- Younger v. Harris, 401 U.S. 37 (1971) (federal courts must refrain from interfering with ongoing state proceedings in certain cases)
- Trainor v. Hernandez, 431 U.S. 434 (1977) (Younger abstention applies to state civil/administrative enforcement proceedings)
- Heck v. Humphrey, 512 U.S. 477 (1994) (limits on §1983 claims that would imply invalidity of convictions)
- Edwards v. Balisok, 520 U.S. 641 (1997) (Heck extended to prison disciplinary proceedings when relief would imply invalidity of original sanction)
- Preiser v. Rodriguez, 411 U.S. 475 (1973) (when habeas is the exclusive federal remedy for collateral attack on custody)
- Patsy v. Board of Regents, 457 U.S. 496 (1982) (nonprisoners need not exhaust state remedies before suing under §1983)
- Wallace v. Kato, 549 U.S. 384 (2007) (a claim accrues when plaintiff has a complete and present cause of action)