No. 22-938

George Washington University v. Jabari Stafford

Lower Court: District of Columbia
Docketed: 2023-03-27
Status: Dismissed
Type: Paid
Response RequestedResponse Waived
Tags: civil-rights civil-rights-act discrimination due-process federal-statute personal-injury personal-injury-claims state-law statute-of-limitations title-vi
Key Terms:
Arbitration SocialSecurity ERISA
Latest Conference: 2023-04-14
Question Presented (AI Summary)

Whether courts should reflexively borrow the state-law general limitations period applicable to all personal-injury claims to govern any claim alleging unlawful discrimination under a federal statute that does not specify its own limitations period

Question Presented (from Petition)

QUESTION PRESENTED This Court has recognized that, where a federal statute creates a claim but does not specify a deadline to assert it, Congress presumptively “intended that the courts apply the most closely analogous statute of limitations under state law.” DelCostello v. International Brotherhood of Teamsters, 462 U.S. 151, 158 (1983); see, e.g., Holmberg v. Armbrecht, 327 U.S. 392, 395 (1946). Respondent brought this suit against petitioner, alleging a violation of Title VI of the Civil Rights Act of 1964, 42 U.S.C. § 2000d et seg.— Spending Clause legislation that prohibits discrimination based on race, color, or national origin in a program that receives federal funding. Title VI contains no express limitations period for private suits. The district court held that the state law most closely analogous to Title VI is the District of Columbia Human Rights Act—a statute that proscribes the same conduct, has the same purpose, offers the same remedies, applies in the same contexts, and is enforced through the same processes as Title VI. The court of appeals reversed. It construed this Court’s precedents as requiring the application of the state-law limitations period for personal-injury claims to any federal civil-rights statute lacking its own express deadline. The court of appeals therefore held that respondent’s claim is subject to the District’s catchall limitations period that encompasses personal-injury claims for which no other time bar is specified. The question presented is as follows: Whether courts should reflexively borrow the state-law general limitations period applicable to all personal-injury claims to govern any claim alleging unlawful discrimination under a federal statute that does not specify its own limitations period.

Docket Entries

2023-05-22
Petition Dismissed - Rule 46.
2023-05-16
Joint stipulation to dismiss the case pursuant to Rule 46.1 filed
2023-04-21
Reply in support of the motion to extend the time to file a response from respondent filed.
2023-04-21
Motion to extend the time to file a response is granted in part and the time is extended to and including May 26, 2023.
2023-04-19
Motion to extend the time to file a response from May 11, 2023 to June 10, 2023, submitted to The Clerk.
2023-04-19
Response to motion to extend the time to file a response from petitioner filed.
2023-04-11
Response Requested. (Due May 11, 2023)
2023-03-29
DISTRIBUTED for Conference of 4/14/2023.
2023-03-28
Waiver of right of respondent Jabari Stafford to respond filed.
2023-03-23

Attorneys

Jabari Stafford
Brian WolfmanGeorgetown Law Appellate Courts Immersion Clinic, Respondent
Brian WolfmanGeorgetown Law Appellate Courts Immersion Clinic, Respondent
The George Washington University
Jason Craig SchwartzGibson, Dunn & Crutcher LLP, Petitioner
Jason Craig SchwartzGibson, Dunn & Crutcher LLP, Petitioner