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Hamilton v. City of Overland Park

United States Court of Appeals, Tenth Circuit
Mar 30, 1984
730 F.2d 613 (10th Cir. 1984)

Summary

holding that Kan. Stat. Ann. § 60-513's two-year statute of limitations applies to § 1983 claims in Kansas

Summary of this case from M.A.C. v. Gildner

Opinion

No. 83-1593.

March 30, 1984.

J.R. Russell of Kansas City, Kan., for plaintiff-appellant.

Kathryn Pruessner Peters, Asst. City Atty., Kansas City, Kan., and Neil R. Shortlidge, First Asst. City Atty., Overland Park, Kan., for defendants-appellees.

Appeal from the United States District Court for the District of Kansas.

Before SETH, Chief Judge, and HOLLOWAY, McWILLIAMS, BARRETT, DOYLE, McKAY, LOGAN and SEYMOUR. Circuit Judges.


This action was brought by Kenneth Hamilton against the City of Overland Park, the City of Kansas City, and two Kansas City municipal employees. Hamilton alleged that he was wrongfully arrested, and sought damages under 42 U.S.C. § 1983 (1976) for denial of his constitutional rights to liberty and due process. He also asserted pendent state law claims for intentional infliction of emotional distress and outrageous conduct. The district court dismissed the action on the pleadings, concluding that the section 1983 claims were barred by the applicable statute of limitations, and that the court therefore lacked pendent jurisdiction over the state law claims. We reverse.

The arrest giving rise to Hamilton's suit occurred on October 12, 1981. Hamilton filed his complaint on November 3, 1982, a little over one year later. In concluding that the civil rights claims were time-barred, the district court applied the one-year limitations period provided by Kan. Stat.Ann. § 60-514(2) (1976), which governs "[a]n action for assault, battery, malicious prosecution, or false imprisonment."

Because Congress has not enacted a statute of limitations expressly applicable to section 1983 claims, the court must adopt the most analogous limitations period provided by state law. See 42 U.S.C. § 1988 (1976); Board of Regents v. Tomanio, 446 U.S. 478, 483-84, 100 S.Ct. 1790, 1794-95, 64 L.Ed.2d 440 (1980). In Garcia v. Wilson, 731 F.2d 640 (10th Cir. 1984) (en banc), decided this day, we considered the method by which an appropriate state statute is to be selected for section 1983 actions. We concluded as a matter of federal law that all section 1983 claims should be characterized as actions for injury to the rights of another. See id. at ___-___. Under Kan.Stat.Ann. § 60-513(a)(4) (1976), "[a]n action for injury to the rights of another, not arising on contract, and not herein enumerated" must be brought within two years. For the reasons set out in Garcia, we hold that the Kansas two-year statute is the most appropriate limitations period. Accordingly, Hamilton's section 1983 actions are timely filed. Because the district court's dismissal of the pendent state law claims rested on its disposition of the civil rights actions, dismissal of these claims on that ground must also be reversed.

The suit is reversed and remanded for further proceedings.


Summaries of

Hamilton v. City of Overland Park

United States Court of Appeals, Tenth Circuit
Mar 30, 1984
730 F.2d 613 (10th Cir. 1984)

holding that Kan. Stat. Ann. § 60-513's two-year statute of limitations applies to § 1983 claims in Kansas

Summary of this case from M.A.C. v. Gildner

holding that the two-year statute of limitations in Kan. Stat. Ann § 60-513 should be applied to section 1983 claims

Summary of this case from Henderson v. Montgomery County, Kansas, Bd.

holding that the two-year statute of limitations in Kan. Stat. Ann § 60513 should be applied to section 1983 claims

Summary of this case from Henderson v. Montgomery County, Kansas, Bd.

applying 2-year Kansas statute governing actions for "injuries to the rights of another"

Summary of this case from Wilson v. Garcia

applying Kansas statute of limitations for "[a]n action for injury to the rights of another, not arising on contract, and not herein enumerated" rather than the statute for claims of "assault, battery, malicious prosecution, or false imprisonment"

Summary of this case from Meade v. Grubbs

noting that the statute of limitations for bringing a section 1983 claim in Kansas is two years, as set out in K.S.A. § 60-513

Summary of this case from Lewis v. Dodge City Cmty. Coll.

applying two-year statute of limitations under K.S.A. § 60-513 to Section 1983 claim

Summary of this case from Taylor v. Osawatomie State Hospital

stating that because Congress has not enacted a statute of limitations applicable to § 1983, all § 1983 claims should be characterized as actions for injury to the rights of another and that Kansas' statute of limitations for such an action is two years

Summary of this case from Herndon v. City of Park City, Kansas

stating that because Congress has not enacted a statute of limitations applicable to § 1983, all § 1983 claims should be characterized as actions for injury to the rights of another and that Kansas' statute of limitations for such an action is two years

Summary of this case from Semsroth v. City of Wichita

applying Kansas personal injury limitation

Summary of this case from Wilson v. Bedford Police Department

applying Kansas personal injury limitation

Summary of this case from Franklin v. City of Kansas City

applying Kansas statute of limitations for "action for injury to the rights of another" to 42 U.S.C. § 1983 claim

Summary of this case from Carrington v. RCA Global Communications, Inc.

designating two-year statute in Kansas

Summary of this case from Chris N. v. Burnsville, Minn.

In Hamilton v. City of Overland Park, 730 F.2d 613 (10th Cir. 1984), cert. den. ___ U.S. ___, 105 S.Ct. 2111, 85 L.Ed.2d 476 (1985), the court of appeals held that the appropriate statute of limitations in Kansas was the two year statute governing actions "for injuries to the rights of another."

Summary of this case from Saldivar v. Cadena

In Hamilton v. City of Overland Park, Kansas, 730 F.2d 613 (10th Cir. 1984), cert. denied, ___ U.S. ___, 105 S.Ct. 2111, 85 L.Ed.2d 476 (U.S. 1985), involving a claim for unlawful arrest, the court applied the Kansas two-year limitations period for "action[s] for injury to the rights of another, not arising on contract, and not herein enumerated," Kan.Stat.Ann. § 60-513(a)(4) (1976), finding that this statute fit nicely with its own holding in Garcia v. Wilson, 731 F.2d 640, that all section 1983 claims "should be characterized as actions for injury to the rights of another."

Summary of this case from Small v. Inhabitants of City of Belfast
Case details for

Hamilton v. City of Overland Park

Case Details

Full title:KENNETH W. HAMILTON, PLAINTIFF-APPELLANT, v. THE CITY OF OVERLAND PARK…

Court:United States Court of Appeals, Tenth Circuit

Date published: Mar 30, 1984

Citations

730 F.2d 613 (10th Cir. 1984)

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