Law School Case Brief
Jones v. City of Boston - No. 03-12130-RGS, 2004 U.S. Dist. LEXIS 12628 (D. Mass. July 9, 2004)
The discovery rule is an equitable doctrine under which a statute of limitations is tolled when a plaintiff has been injured by an inherently unknowable wrong. Under the discovery rule, a limitations period starts running when events occur or facts surface which would cause a reasonably prudent person to become aware that he or she had been harmed.
In May 1995, plaintiff Erick Jones was arrested by police officers from defendant City of Boston after being accused by an adolescent neighbor of a sexual assault. On May 24, 1995, the Suffolk County Grand Jury returned a three-count indictment charging Jones with indecent assault and battery on a person 14 years of age or older; rape and abuse of a child under 16 years of age; and assault with intent to rape a child under age 16. Thereafter, Jones sued in federal district court against the City of Boston, two (initially) unnamed police officers, the Suffolk County District Attorney's Office (SCDAO), and the Suffolk County District Attorney. According to Jones, the grand jury transcript, the police reports, and the alleged victim's videotaped statement contained exculpatory information, and the prosecution allegedly failed to make that information available for his defense, in violation of 42 U.S.C.S. §§ 1981, 1983, 1985, 1986, and 1988, Mass. Gen. Laws ch. 258, § 2, and common law principles. However, Jones did not file his complaint until more than eight years after the acts occurred. Defendants filed a motion to dismiss on grounds that the claims were barred by the applicable statutes of limitations and the district attorney and his assistants were entitled to Eleventh Amendment immunity and absolute prosecutorial immunity.
Should Jones' claim be dismissed because: (i) they were barred by the statute of limitations, and; (ii) the district attorney and his assistants were entitled to Eleventh Amendment immunity and absolute prosecutorial immunity?
The court noted that the applicable statute of limitations were all for three-year periods, Mass. Gen. Laws ch. 260, § 2A, and because the court found that Jones' criminal attorney had discovery of the relevant information at the time of his prosecution, knowledge of the facts had to be imputed to Jones as of that time. Furthermore, the court found the substantive grounds for dismissal were meritorious. According to the Court, absolute immunity protected the district attorney and his assistants for the prosecution of the indictment.
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