Fake evidence lawsuit deadlines
McDonough v. Smith
In brief
The Supreme Court overturned the Second Circuit and sent the case back, ruling that McDonough’s filing deadline began when he was acquitted at his second trial.
- Where it stands
- Decided
Decided 6-3 · June 20, 2019 · Opinion by Justice Sotomayor
- What it’s about
- Robert McDonough sued under a federal civil-rights law, claiming an official fabricated evidence used against him in criminal proceedings.
- Who it affects
- For McDonough, the filing deadline began at his acquittal, not when he learned of the allegedly tainted evidence.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that the deadline for his suit began when he was acquitted at his second trial, overturned the Second Circuit’s ruling, and sent the case back to the lower court (remanded).
McDonough alleged that an official fabricated evidence used against him in criminal proceedings.
McDonough brought his claim under Section 1983, a federal civil-rights law.
Question presented
Whether the statute of limitations for a Section 1983 claim based on fabrication of evidence in criminal proceedings begins to run when those proceedings terminate in the defendant's favor (as the majority of circuits has held) or whether it begins to run when the defendant becomes aware of the tainted evidence and its improper use (as the Second Circuit held below).
What the Court decided
Holding
The statute of limitations for McDonough’s §1983 fabricatedevidence claim began to run when the criminal proceedings against him terminated in his favor—that is, when he was acquitted at the end of his second trial. 898 F. 3d 259, reversed and remanded.
- Result
- Reversed
The Court's reasoning
The Court treated the favorable end of the criminal case as the trigger for the filing deadline; McDonough’s acquittal at his second trial was that point.
The vote
From the opinions
“McDonough’s failure to specify which constitutional right the respondent allegedly violated profoundly complicates our inquiry.”
What's next
The case returns to the Second Circuit to continue under the Supreme Court’s timing ruling.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Opinion added: McDonough
Opinion added: opinion
Brief added: Petition
Brief added: Questions Presented
More questions
- What deadline rule did the Second Circuit use?
- It started the filing clock when McDonough became aware of the tainted evidence and its improper use.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.