Daniels v. University of Michigan

CourtDistrict Court, E.D. Michigan
DecidedFebruary 10, 2025
Docket2:24-cv-11686
StatusUnknown

This text of Daniels v. University of Michigan (Daniels v. University of Michigan) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daniels v. University of Michigan, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

DAVID DANIELS,

Plaintiff, Case No. 24-cv-11686

v. Hon. Sean F. Cox UNIVERSITY OF MICHIGAN ET AL., United States District Court Judge

Defendants. ___________________________________/

OPINION & ORDER GRANTING IN PART AND DENYING IN PART UNIVERSITY OF MICHIGAN DEFENDANTS’ MOTION TO DISMISS (ECF No. 31) AND DENYING DEFENDANT LIPIAN’S MOTION TO DISMISS (ECF No. 32)

In this federal-question action, Plaintiff David Daniels attempts to plead two federal claims and several supplemental state-law claims against several defendants. But Daniels’s federal claims are barred by the applicable statute of limitations and are not subject to equitable tolling, so the Court shall dismiss those claims with prejudice and decline supplemental jurisdiction over Daniels’s state-law claims. BACKGROUND Daniels was a music professor at the University of Michigan (“U of M”) until 2018 when, he alleges, he was fired for sexual misconduct without adequate process. Daniels also alleges that he is homosexual, and that similarly situated heterosexual professors accused of similar misconduct kept their jobs at U of M. Daniels now brings due-process (Count I) and equal- protection (Count II) claims under 42 U.S.C. § 1983 against seven current and former U of M faculty and staff members (together, “Individual Defendants”) for alleged misconduct in connection with his termination. Daniels also brings state-law claims (Counts III–VIII) against Individual Defendants, U of M, the U of M Board of Regents, and an individual named David Lipian. Daniels concedes that his § 1983 claims are barred by the applicable statute of limitations but maintains that he is entitled to equitable tolling because he was charged with sexual assault in the State of Texas in October 2022, he pled guilty to that on August 4, 2023, and he filed this action as soon as he could in June 2024.1 Individual Defendants disagree and move to dismiss Daniels’s § 1983 claims as time barred. Individual Defendants also move to dismiss Daniels’s state-law claims against them, and U of M and the U of M Board of Regents join that motion. The remaining defendant, Lipian, filed his own motion to dismiss Daniels’s state-law claims against him. Briefing on the defendants’ motions to dismiss has concluded, and the Court heard oral argument. For the following reasons, the Court shall dismiss Daniels’s § 1983 claims with prejudice and decline supplemental jurisdiction over his state-law claims. STANDARD OF REVIEW “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). And “if [a] plaintiff[’s] complaint contains facts which satisfy the elements of the defendant’s affirmative defense, [a] district court may apply the defense.” Estate of Barney v. PNC Bank, Nat’l Ass’n,

714 F.3d 920, 926 (6th Cir. 2013).

1 Although the operative complaint doesn’t discuss the dates when Daniels was charged and pled guilty in his Texas criminal prosecution, Individual Defendants offer a public record that does. (ECF No. 31-9); see also New Eng. Health Care Emps. Pension Fund v. Ernst & Young, LLP, 336 F.3d 495, 501 (6th Cir. 2003) (“A court that is ruling on a Rule 12(b)(6) motion may consider materials in addition to the complaint if such materials are public records or are otherwise appropriate for the taking of judicial notice.”). ANALYSIS Daniels concedes that his § 1983 claims are barred by the applicable statute of limitations,2 but the parties dispute whether Daniels is entitled to equitable tolling.3 Because § 1983 claims “lack express statutes of limitations,” courts “borrow the personal-injury statute of limitations from the state in which the claim arose.” Wershe v. City of Detroit, 112 F.4th 357,

365 (6th Cir. 2024) (quoting Zappone v. United States, 870 F.3d 551, 559 (6th Cir. 2017)), cert. denied, No. 24-545, 2025 WL 247463 (U.S. Jan. 21, 2025). And “state[] equitable tolling principles likewise govern § 1983 claims” unless the state’s “tolling rules are ‘inconsistent with the federal policy underlying [§ 1983].’” Id. at 371 (alteration in original) (quoting Bishop v. Child.’s Ctr. for Developmental Enrichment, 618 F.3d 533, 537 (6th Cir. 2010)). The parties agree that Daniels’s § 1983 claims arose in Michigan, and Michigan’s statute of limitations for personal injury claims is expressly prescribed by statute. See id. at 365; see also Mich. Comp. Laws § 600.5805(2) (2025) (“[T]he period of limitations is 3 years after the time of the death or injury for all actions to recover damages for the death of a person or for injury to a person or property.”). “And under Michigan law, an express statute of limitations

ordinarily cannot be equitably tolled.” Wershe, 112 F.4th at 371. Daniels doesn’t point to any

2 Daniels argued in the papers that his § 1983 claims arose outside the applicable statute of limitations based on the continuing violations doctrine, but Daniels conceded at oral argument that the applicable statute of limitations bars his claims. 3 Individual Defendants also argued that Daniels’s § 1983 claims for injunctive relief fail because he seeks such relief against them in their official capacities, and official-capacity defendants aren’t “persons” amenable to suit under § 1983. This argument fails because “a state official in his or her official capacity, when sued for injunctive relief, [is] a person under § 1983.” Will v. Mich. Dep’t of State Police, 491 U.S. 58, 71 n.10 (1989). In his response brief, Daniels conceded that Will barred his claims for injunctive relief under § 1983. (ECF No. 35, PageID.934 (“Plaintiff agrees that neither a State nor its officials acting in their official capacities are persons under §1983.”)). But Daniels nevertheless maintained at oral argument that his claims for injunctive relief arose under § 1983. The Court thus presumes that Daniels seeks injunctive relief under § 1983 and not, say, Ex parte Young, 209 U.S. 123 (1908). Michigan law showing otherwise, and therefore his § 1983 claims are time barred unless Michigan’s tolling principles are inconsistent with the federal policy underlying § 1983. The Sixth Circuit recently declined to consider whether Michigan’s tolling rules are inconsistent with the federal policy underlying § 1983. See id. The Sixth Circuit did, however, explain that if Michigan’s tolling rules conflict with § 1983’s purpose, then the five factors that

courts consider in deciding whether to toll the statute of limitations for claims arising under the Federal Tort Claims Act (“FTCA”) would control. See id. at 364–71.

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Will v. Michigan Department of State Police
491 U.S. 58 (Supreme Court, 1989)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Todd Zappone v. United States
870 F.3d 551 (Sixth Circuit, 2017)

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Bluebook (online)
Daniels v. University of Michigan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniels-v-university-of-michigan-mied-2025.