AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• Plaintiffs Daron Scott and Duryea Scott filed a lawsuit against Doña Ana County and several of its officers and employees, alleging civil rights violations and claims under the New Mexico Tort Claims Act. The case stemmed from two raids conducted by Defendants on August 8 and 10, 2007, on properties owned by the Plaintiffs in New Mexico and Texas, during which the Plaintiffs and their properties were searched, and their dogs were seized without warrants. The Plaintiffs were later arrested on October 18, 2007, based on allegations of dog fighting (paras 2-3).

Procedural History

• District Court of Doña Ana County, James T. Martin, District Judge: Dismissed Plaintiffs' complaint for statute of limitations violation (N/A).
• United States District Court for the District of New Mexico: Dismissed Plaintiffs’ federal claims with prejudice and remanded the remaining state claims to the First Judicial District Court (para 4).
• First Judicial District Court: Dismissed Plaintiffs’ complaint without prejudice based on improper venue (para 5).
• Third Judicial District Court in Doña Ana County: Dismissed Plaintiffs’ re-filed case based on statute of limitations expiration (para 5).

Parties' Submissions

• Plaintiffs: Argued that seven of their fourteen claims were governed by a three-year statute of limitations and that the remaining claims were timely filed within a two-year statute of limitations. They also contended that the district court should have considered the dates of alleged wrongful acts for determining the statute of limitations and argued for equitable tolling (paras 6-7).
• Defendants: Filed a motion to dismiss the complaint, claiming that Plaintiffs’ claims were barred by the statute of limitations, which had expired on July 11, 2011 (para 5).

Legal Issues

• Whether the district court erred in applying a two-year statute of limitations to seven of the Plaintiffs' claims instead of a three-year statute of limitations.
• Whether the district court accurately determined the date on which the statute of limitations began to run for six of the Plaintiffs' claims, resulting in their erroneous dismissal.
• Whether equity demands that Plaintiffs' claims should survive notwithstanding the statute of limitations violation (paras 8-9).

Disposition

• The Court of Appeals affirmed the district court’s dismissal of Plaintiffs' complaint for violation of the statute of limitations (para 19).

Reasons

• Per Jonathan B. Sutin (Michael E. Vigil, Judge, Linda M. Vanzi, Judge concurring): The Court held that the constitutional claims were subject to a two-year statute of limitations under the Tort Claims Act, rejecting Plaintiffs' argument for a three-year statute based on the New Mexico Constitution and federal civil rights jurisprudence. The Court also found that the district court correctly determined the accrual dates for the non-constitutional claims based on the dates of the raids, and thus, the claims were not filed within the applicable statute of limitations. The Court declined to consider Plaintiffs' equity argument raised only in their reply brief (paras 10-18).