McDonough v. Smith

McDonough v. Smith
Supreme Court of the United States
Argued April 17, 2019 Decided June 20, 2019
Full case name	Edward G. McDonough v. Youel Smith, Individually and as Special District Attorney for the County of Rensselaer, New York (aka Trey Smith)
Docket no.	18-485
Citations	588 U.S. ___ (more) 139 S. Ct. 2149; 204 L. Ed. 2d 506
Case history
Prior	Motion to dismiss granted, McDonough v. Smith, No. 1:15-cv-01505, 2016 WL 5717263 (N.D.N.Y. Sept. 30, 2016); motion for reconsideration denied, 2017 WL 1901962 (N.D.N.Y. May 8, 2017); affirmed, 898 F.3d 259 (2d Cir. 2018); cert, granted, 139 S. Ct. 915 (2019).
Holding
The statute of limitations for a §1983 fabricated-evidence claim began to run when the criminal proceedings end in the §1983 plaintiff's favor.
Court membership
Chief Justice John Roberts Associate Justices Clarence Thomas · Ruth Bader Ginsburg Stephen Breyer · Samuel Alito Sonia Sotomayor · Elena Kagan Neil Gorsuch · Brett Kavanaugh
Case opinions
Majority	Sotomayor, joined by Roberts, Ginsburg, Breyer, Alito, Kavanaugh
Dissent	Thomas, joined by Kagan, Gorsuch
Laws applied
42 U.S.C. § 1983

McDonough v. Smith, 588 U.S. ___ (2019), was a United States Supreme Court case from the October 2018 term. In a 6–3 ruling, the Court held that the 3-year statute of limitations for a fabrication of evidence civil lawsuit under section 1983 of the Civil Rights Act begins to run when the criminal case ends in the plaintiff's favor.^[1]

This case was notable as a victory for criminal defendants; the precedent it set would make it easier to sue prosecutors and police for fabricating evidence against defendants.^[2] The Court's ruling also resolves a circuit split between United States Court of Appeals for the Second Circuit and other federal appeals courts.^[3]