Because 42 U.S.C. section 1983 lacks its own statute of limitations, courts determine the deadline for commencing civil rights actions by borrowing the most appropriate limitation prescribed by state law. Courts have used a variety of techniques to choose among arguably relevant state limitation provisions. This diversity has produced "conflict, confusion, and uncertainty concerning the appropriate statute of limitations to apply to this most important, and ubiquitous, civil rights statute.
John R. Pagan,
Virginia's Statute of Limitations For Section 1983 Claims After Wilson v. Garcia,
U. Rich. L. Rev.
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