Jim's Car Wash v. City of Dallas

CourtDistrict Court, N.D. Texas
DecidedAugust 24, 2022
Docket3:21-cv-01746
StatusUnknown

This text of Jim's Car Wash v. City of Dallas (Jim's Car Wash v. City of Dallas) is published on Counsel Stack Legal Research, covering District Court, N.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jim's Car Wash v. City of Dallas, (N.D. Tex. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

JIM’S CAR WASH, FREDDY DAVENPORT, and DALE DAVENPORT,

Plaintiffs,

Civil Action No. 3:21-CV-01746-K v.

CITY OF DALLAS,

Defendant.

MEMORANDUM OPINION AND ORDER

Before the Court are City of Dallas’s Motion to Dismiss for Failure to State a Claim (the “Motion” or the “Motion to Dismiss”) (Doc. No. 43), Plaintiffs’ Response to City Defendant’s Motion to Dismiss (the “Response”) (Doc. No. 50), and City of Dallas’s Reply Brief in Support of Its Motions to Dismiss (the “Reply”) (Doc. No. 52). The Court has carefully considered the Motion, the Response, the Reply, the associated briefs and appendices, and the applicable law. Because the parties agree that this lawsuit was filed untimely, and because Plaintiffs have not sufficiently established a basis for equitable tolling, the Court GRANTS the Motion. Jim’s Car Wash, Freddy Davenport, and Dale Davenport (collectively, “Plaintiffs”) bring this action against the City of Dallas (“Defendant” or the “City”) under 42 U.S.C. § 1983 for a number of alleged constitutional violations. See Doc. No. 36 at 14-16. Plaintiffs also allege a conspiracy to interfere with civil rights claim under 42 U.S.C. § 1985. Id. at 16. In its Motion to Dismiss, the City advances various defenses including that Plaintiffs’ claims are time-barred per the relevant statute of

limitations. Doc. No. 44 at 11-12. “The statute of limitations for a suit brought under § 1983 is determined by the general statute of limitations governing personal injuries in the forum state.” Piotrowski v. City of Houston, 237 F.3d 567, 576 (5th Cir. 2001). The same is true for claims brought under 42 U.S.C. § 1985. Helton v. Clements, 832 F.2d 332, 334 (5th Cir. 1987).

The Texas general personal injury limitations period is two years. Tex. Civ. Prac. & Rem. Code Ann. § 16.003. Thus, Plaintiffs had two years from the date or dates their claims accrued to timely file suit. When did Plaintiffs’ claims accrue? While Texas law provides the relevant

statute of limitations, “federal law determines when a cause of action accrues.” Helton, 832 F.2d at 334. The Court need not delve too deeply into the accrual analysis, however, because Plaintiffs admit that “The application of a two-year statute of limitations requires Plaintiffs’ filing to have occurred on June 14, 2021. As Defendant

notes, Plaintiffs filed on July 27, 2021.” Doc. No. 50 at 8. It is not immediately clear to the Court how Plaintiffs arrive at the June 14, 2021, expiry date. Regardless, Plaintiffs agree with Defendant that their federal lawsuit was filed sometime after the limitation period had run. But this is not the end of the inquiry as Plaintiffs argue that their claims should

not be time-barred per the doctrine of equitable tolling. “Because the Texas statute of limitations is borrowed in § 1983 cases, Texas’ equitable tolling principles also control.” Rotella v. Pederson, 144 F.3d 892, 897 (5th Cir. 1998) (citing Board of Regents of Univ. of

State of N.Y. v. Tomanio, 446 U.S. 478, 485 (1980)). Considering that the Texas statute of limitations is also borrowed in § 1985 cases, the Court applies the same logic to Plaintiffs’ § 1985 claim. Texas case law on equitable tolling is seemingly limited, though Texas courts do recognize the doctrine—albeit in what appear to be fairly narrow circumstances:

“Equitable tolling applies in situations where a claimant actively pursued his judicial remedies but filed a defective pleading during the statutory period, or where a complainant was induced or tricked by his adversary’s misconduct into allowing filing deadlines to pass.” Bailey v. Gardner, 154 S.W.3d 917, 920 (Tex. App.—Dallas 2005,

no pet.) (citing Czerwinski v. Univ. of Tex. Health Sci. Ctr. at Houston Sch. of Nursing, 116 S.W.3d 119, 122–23 (Tex.App.-Hous. [14th Dist.] 2002, pet. denied)); see also Hughes v. Mahaney & Higgins, 821 S.W.2d 154, 157 (Tex. 1991); Zive v. Sandberg, 644 S.W.3d 169, 175 (Tex. 2022). Neither of these circumstances are present here, and Plaintiffs

make no argument to the contrary. “In § 1983 actions, . . . a state statute of limitations and the coordinate tolling rules are more than a technical obstacle to be circumvented if possible. In most cases, they are binding rules of law.” Tomanio, 446 U.S. at 484. That said, a federal court may not apply a state’s tolling rules when they are inconsistent with federal policy. F.D.I.C.

v. Dawson, 4 F.3d 1303, 1309 (5th Cir. 1993) (citing Tomanio, 446 U.S. at 485-86). According to the Fifth Circuit in Rotella, “Although a state’s tolling provisions cannot be inconsistent with the policies underlying § 1983, there is no authority for the

proposition that it must be consistent with the federal tolling provisions. . . . [W]e see no basis for holding[] that the Texas tolling laws are inconsistent with policies underlying § 1983.” 144 F.3d at 987 (citing Rubin v. O’Koren, 644 F.2d 1023, 1025 (5th Cir. 1981)). Plaintiffs urge the Court to apply the federal equitable tolling provision

reiterated in Holland v. Florida: “A ‘petitioner’ is ‘entitled to equitable tolling’ if he shows ‘(1) that he has been pursuing his rights diligently, and (2) that some extraordinary circumstance stood in his way’ and prevented timely filing.” 560 U.S. 631 (citing Pace v. DiGuglielmo, 544 U.S. 408, 418 (2005)). The Court notes, however,

that Holland asked “whether federal courts may excuse a petitioner’s failure to comply with federal timing rules, an inquiry that does not implicate a state court’s interpretation of state law.” Id. at 650. But even if the federal equitable tolling provision applied, the Court does not believe that Plaintiffs have sufficiently satisfied either of its

requirements. See In re Deepwater Horizon, No. 20-30673, 2021 WL 4888395, at *2 (5th Cir. Oct. 19, 2021) (citing Pace, 544 U.S. at 418) (“The party seeking equitable tolling bears the burden of satisfying these requirements.”). First, Plaintiffs argue that an extraordinary circumstance stood in their way and prevented timely filing. Doc. No. 50 at 8-9. Specifically, Plaintiffs state: [The] delay in Plaintiffs’ filing was caused when Plaintiff Dale Davenport suffered a heart attack the weekend prior to June 1, 2021. Plaintiff Dale Davenport and the undersigned were preparing Plaintiffs’ federal complaint, but required additional information from Plaintiffs, including a declaration from Plaintiff Dale Davenport.

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Related

Rotella v. Pederson
144 F.3d 892 (Fifth Circuit, 1998)
Piotrowski v. City of Houston
237 F.3d 567 (Fifth Circuit, 2001)
Board of Regents of Univ. of State of NY v. Tomanio
446 U.S. 478 (Supreme Court, 1980)
Pace v. DiGuglielmo
544 U.S. 408 (Supreme Court, 2005)
Betty Q. Keasler Rubin v. Marie L. O'KOren
644 F.2d 1023 (Fifth Circuit, 1981)
Bailey v. Gardner
154 S.W.3d 917 (Court of Appeals of Texas, 2005)
Hughes v. Mahaney & Higgins
821 S.W.2d 154 (Texas Supreme Court, 1992)

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