McDonough v. Smith
Headline: Court rules that civil claims for fabricated evidence start the statute of limitations only after criminal proceedings end favorably, allowing defendants to sue after acquittal but not during active prosecutions.
Holding: The Court held that the three-year time limit for a civil suit claiming fabricated evidence does not begin until the criminal case ends in the defendant’s favor, here when he was acquitted.
- Delays most lawsuits alleging fabricated evidence until after criminal cases end favorably.
- Reduces parallel civil suits against prosecutors during active prosecutions.
- Requires accused people to wait until acquittal before filing many civil claims.
Summary
Background
Edward McDonough, a local elections worker, was accused after an investigation into forged absentee ballots. A prosecutor specially appointed to the case allegedly used fabricated affidavits, coached witnesses, and relied on a suspect DNA analysis. McDonough faced two trials, the first ended in a mistrial and the second in an acquittal on December 21, 2012. He sued the prosecutor under 42 U.S.C. §1983 on December 18, 2015, claiming the prosecutor had fabricated evidence; lower courts held the claim untimely.
Reasoning
The Court addressed when the statute of limitations begins for a civil claim that accuses a government official of fabricating evidence. The Justices said the claim is most like the old tort of malicious prosecution, which only accrues after the criminal case ends in the defendant’s favor. To avoid parallel civil and criminal suits and collateral attacks on prosecutions, the Court held the limitations clock does not start until the criminal proceedings terminate favorably, here when McDonough was acquitted. The opinion distinguished other kinds of claims that can run earlier and noted practical problems if plaintiffs had to sue while prosecuted.
Real world impact
People who later learn that officials fabricated evidence generally cannot bring §1983 suits until their criminal cases end favorably. This reduces the chance of simultaneous civil suits during active prosecutions and preserves comity between criminal and civil courts. The decision leaves open some questions about different legal theories and what counts as a favorable ending.
Dissents or concurrances
Justice Thomas, joined by two Justices, dissented, arguing the Court should have first decided what specific constitutional right McDonough alleged and that the case was improvidently granted.
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