Statute of limitations

A statute of limitations, known in civil law systems as a prescriptive period, is a law passed by a legislative body to set the maximum time after an event within which legal proceedings may be initiated.[1]

When the time specified in a statute of limitations passes, a claim might no longer be filed or, if filed, may be subject to dismissal if the defense against that claim is raised that the claim is time-barred as having been filed after the statutory limitations period. When a statute of limitations expires in a criminal case, the courts no longer have jurisdiction. Most crimes that have statutes of limitations are distinguished from serious crimes as these may be brought at any time.[2]

In civil law systems, such provisions are typically part of their civil or criminal codes. The cause of action dictates the statute of limitations, which can be reduced (or extended) to ensure a fair trial.[3] The intention of these laws is to facilitate resolution within a "reasonable" length of time.[4] What amount of time is considered "reasonable" varies from country to country, and within countries such as the United States from state to state.[5][6] Within countries and states, the statute of limitations may vary from one civil or criminal action to another. Some nations have no statute of limitations whatsoever.

Analysis of a statute of limitations also requires the examination of any associated statute of repose, tolling provisions, and exclusions.

Applications

Common law legal systems can include a statute specifying the length of time within which a claimant or prosecutor must file a case. In some civil jurisdictions (e.g., California),[1] a case cannot begin after the period specified, and courts have no jurisdiction over cases filed after the statute of limitations has expired. In some other jurisdictions (e.g., New South Wales, Australia), a claim can be filed which may prove to have been brought outside the limitations period, but the court will retain jurisdiction in order to determine that issue, and the onus is on the defendant to plead it as part of their defence, or else the claim will not be statute barred.

Once filed, cases do not need to be resolved within the period specified in the statute of limitations.

Purpose

The purpose and effect of statutes of limitations are to protect defendants. There are three reasons for their enactment:[7]

  • A plaintiff with a valid cause of action should pursue it with reasonable diligence.
  • By the time a stale claim is litigated, a defendant might have lost evidence necessary to disprove the claim.
  • Litigation of a long-dormant claim may result in more cruelty than justice.

In Classical Athens, a five-year statute of limitations was established for all cases except homicide and the prosecution of non-constitutional laws (which had no limitation). Demosthenes wrote that these statutes of limitations were adopted to control "sycophants" (professional accusers).[8]

The limitation period generally begins when the plaintiff's cause of action accrues, meaning the date upon which the plaintiff is first able to maintain the cause of action in court, or when the plaintiff first becomes aware of a previous injury (for example, occupational lung diseases such as asbestosis).

Statute of repose
Main article: Statute of repose

A statute of repose limits the time within which an action may be brought based upon when a particular event occurred (such as the completion of construction of a building or the date of purchase of manufactured goods), and does not permit extensions. A statute of limitations is similar to a statute of repose, but may be extended for a variety of reasons (such as the minority of the victim).

For example, most U.S. jurisdictions have passed statutes of repose for construction defects.[9][10][11][12] If a person receives an electric shock due to a wiring defect that resulted from the builder's negligence during construction of a building, the builder is potentially liable for damages if the suit is brought within the time period defined by the statute, normally starting with the date that construction is substantially completed. After the statutory time period has passed, without regard to the nature or degree of the builder's negligence or misconduct, the statute of repose presents an absolute defense to the claim.

Statutes of repose are sometimes controversial; manufacturers contend that they are necessary to avoid unfair litigation and encourage consumers to maintain their property. Alternatively, consumer advocates argue that they reduce incentives to manufacture durable products and disproportionately affect the poor, because manufacturers will have less incentive to ensure low-cost or "bargain" products are manufactured to exacting safety standards.

Tolling and the discovery rule
Further information: Tolling (law) and discovery (law)

Many jurisdictions toll or suspend the limitation period under certain circumstances such as if the aggrieved party (plaintiff) was a minor or filed a bankruptcy proceeding. In those instances, the running of limitations is tolled, or paused, until the condition ends. Equitable tolling may also be applied if an individual may intimidate a plaintiff into not reporting or has been promised a suspended period.

The statute of limitations may begin when the harmful event, such as fraud or injury, occurs or when it is discovered. The US Supreme Court has described the "standard rule" of when the time begins as "when the plaintiff has a complete and present cause of action." The rule has existed since the 1830s.[13] A "discovery rule" applies in other cases (including medical malpractice), or a similar effect may be applied by tolling.

As discussed in Wolk v. Olson, the discovery rule does not apply to mass media such as newspapers and the Internet; the statute of limitations begins to run at the date of publication. In 2013, the US Supreme Court of the United States unanimously ruled in Gabelli v. SEC that the discovery rule does not apply to U.S. Securities and Exchange Commission's investment-advisor-fraud lawsuits since one of the purposes of the agency is to root out fraud.[14]

In private civil matters, the limitation period may generally be shortened or lengthened by agreement of the parties. Under the Uniform Commercial Code, the parties to a contract for sale of goods may reduce the limitation period to one year but not extend it.

Limitation periods that are known as laches may apply in situations of equity; a judge will not issue an injunction if the requesting party waited too long to ask for it. Such periods are subject to broad judicial discretion.

For US military cases, the Uniform Code of Military Justice (UCMJ) states that all charges except those facing court-martial on a capital charge have a five-year statute of limitations. If the charges are dropped in all UCMJ proceedings except those headed for general court-martial, they may be reinstated for six months after which the statute of limitations has run out.

Prescription
Main article: Extinctive prescription

In civil law countries, almost all lawsuits must be brought within a legally-determined period at the end of which the right of action is extinguished. This is known as liberative or extinctive prescription. Under Italian[15] and Romanian law,[16] criminal trials must be ended within a time limit.

In criminal cases, the public prosecutor must lay charges within a time limit which varies by jurisdiction and varies based on the nature of the charge; in many jurisdictions, there is no statute of limitations for murder.[2] Over the last decade of the 20th century, many United States jurisdictions significantly lengthened the statute of limitations for sex offenses, particularly against children, as a response to research and popular belief that a variety of causes can delay the recognition and reporting of crimes of this nature.

Common triggers for suspending the prescription include a defendant's fugitive status or the commission of a new crime. In some jurisdictions, a criminal may be convicted in absentia.[17] Prescription should not be confused with the need to prosecute within "a reasonable delay" as obligated by the European Court of Human Rights.

Laws by region

International crimes

Under international law, genocide, crimes against humanity and war crimes are usually not subject to the statute of limitations as codified in a number of multilateral treaties.[18] States ratifying the Convention on the Non-Applicability of Statutory Limitations to War Crimes and Crimes Against Humanity agree to disallow limitations claims for these crimes. In Article 29 of the Rome Statute of the International Criminal Court, genocide, crimes against humanity and war crimes "shall not be subject to any statute of limitations".

Australia

Victoria

The Limitations Act of 1958 allows 12 years for victims of child abuse to make a claim, with age 37 the latest at which a claim can be made. The police submitted evidence[19] to a commission, the Victorian Inquiry into Church and Institutional Child Abuse (in existence since 2012) indicating that it takes an average of 24 years for a survivor of child sexual abuse to go to the police.[20] According to Attorney General Robert Clark, the government will remove statutes of limitations on criminal child abuse; survivors of violent crime should be given additional time, as adults, to deal with the legal system.[21] Offenders of minors and the disabled have used the statute of limitations to avoid detection and prosecution, moving from state to state and country to country; an example presented to the Victorian Inquiry was the Christian Brothers.[22]

An argument for abolishing statutes of limitations for civil claims by minors and people under guardianship is ensuring that abuse of vulnerable people would be acknowledged by lawyers, police, organisations and governments, with enforceable penalties for organisations which have turned a blind eye in the past. Support groups such as SNAP Australia,[23] Care Leavers Australia Network[24] and Broken Rites have submitted evidence to the Victoria inquiry,[25] and the Law Institute of Victoria[26] has advocated changes to the statute of limitations.

Canada

For crimes other than summary conviction offences, there is no statute of limitations in Canadian criminal law and warrants have remained outstanding for more than 20 years.[27]

For indictable (serious) offences such as major theft, murder, kidnapping or sexual assault, a defendant can be charged at any future date;[28] In sexual abuse cases in particular, men and women have been charged and convicted up to 5 decades after the abuse had been committed.[29] [30] [31]

Civil law limitations vary by province,[32] with Ontario introducing the Limitations Act, 2002 on January 1, 2004.[33]

Germany

In Germany, the statute of limitations on crimes varies by type of crime, with the highest being 30 years for voluntary manslaughter (Totschlag). Murder, genocide, crimes against humanity, war crimes and crime of aggression have no statute of limitations.

Murder used to have 20 years' statute of limitations, which was then extended to 30 years in 1969. The limitations were abolished altogether in 1979, to prevent Nazi criminals from avoiding criminal liability.

For most other criminal offences, the statute of limitations is set by Section 78(3) of the Criminal Code (Strafgesetzbuch) as follows:

  • 30 years for offences punishable by a maximum term of imprisonment for life;
  • 20 years for offences punishable by a maximum term of imprisonment of over 10 years but not by imprisonment for life;
  • 10 years for offences punishable by a maximum term of imprisonment of over 5 years but no more than 10 years;
  • 5 years for offences punishable by a maximum term of imprisonment of over 1 year but no more than 5 years;
  • 3 years for all other offences.[34]

In the civil code (Bürgerliches Gesetzbuch), the regular statute of limitations is three years (plus the time until the end of the calendar year); however, different terms between two and thirty years may apply in specific situations. For example, the term is only two years for claims for alleged defects of purchased goods, but 30 years for claims resulting from a court judgement (such as awarded damages).

India

The statute of limitations in India is defined by the Limitations Act, 1963.[35]

The statute of limitations for criminal offences is governed by Sec. 468 of the Criminal Procedure Code.

Ireland
Main article: Statute of Limitations in Ireland

Norway

The statute of limitations on murder was abolished by a change in law on 1 July 2014, causing any murders committed after 1 July 1989 to have no statute of limitations. This led to the national police force implementing a new investigation group for old cases called the "Cold Case" group. The law was also changed to let cases involving domestic violence, forced marriage, human trafficking and genital mutilation to count from the day the defendant turns 18 years old. Cases where the statute of limitations has already passed can not be extended due to the constitution preventing it.[36]

South Korea

In July 2015, the National Assembly abolished a 25-year limit on first degree murder; it had previously been extended from 15 to 25 years in December 2007.

United Kingdom
Main articles: Limitation periods in the UK and Limitation Act 1980

Unlike other European countries, the United Kingdom has no statute of limitations for any criminal offence, except for summary offences (offences tried in the magistrates’ court). In these cases, criminal proceedings must be brought within 6 months.

United States

In the United States, statutes of limitations apply to both civil lawsuits and criminal prosecutions.[2] Statutes of limitations vary significantly between U.S. jurisdictions.

Retroactive extensions

In Stogner v. California the Supreme Court of the United States held by a 5-4 majority that California's retroactive extension of the statute of limitations for sexual offenses committed against minors was an unconstitutional ex post facto law.[37]

Civil statutes

A civil statute of limitations applies to a non-criminal legal action, including a tort or contract case.[5] If the statute of limitations expires before a lawsuit is filed, the defendant may raise the statute of limitations as an affirmative defense to seek dismissal of the charge. The exact time period depends on both the state and the type of claim (contract claim, personal injury, fraud etc.). Most fall in the range of one to ten years, with two to three years being most common.

Criminal statutes

A criminal statute of limitations defines a time period during which charges must be initiated for a criminal offense.[38][2] If a charge is filed after the statute of limitations expires, the defendant may obtain dismissal of the charge.[39]

Initiation of charges

The statute of limitations in a criminal case only runs until a criminal charge is filed and a warrant issued, even if the defendant is a fugitive.[40]

When the identity of a defendant is not known, some jurisdictions provide mechanisms to initiate charges and thus stop the statute of limitations from running. For example, some states allow an indictment of a John Doe defendant based upon a DNA profile derived from evidence obtained through a criminal investigation.[41] Although rare, a grand jury can issue an indictment in absentia for high-profile crimes to get around an upcoming statute of limitations deadline. One example is the skyjacking of Northwest Orient Airlines Flight 305 by D.B. Cooper in 1971. The identity of D. B. Cooper remains unknown to this day, and he was indicted under the name "John Doe, aka Dan Cooper." [42]

Heinous crimes

Crimes considered heinous by society have no statute of limitations.[2] Although there is usually no statute of limitations for murder (particularly first-degree murder), judges have been known to dismiss murder charges in cold cases if they feel the delay violates the defendant's right to a speedy trial.[43] For example, waiting many years for an alibi witness to die before commencing a murder trial would be unconstitutional. In 2003, the U.S. Supreme Court in Stogner v. California ruled that the retroactive extension of the statute of limitations for sexual offenses committed against minors was an unconstitutional ex post facto law.[44]

Military law

Under the U.S. Uniform Code of Military Justice (UCMJ), desertion has no statute of limitations.[45]

Maritime Injury Law

Under 46 U.S. Code § 30106, "Except as otherwise provided by law, a civil action for damages for personal injury or death arising out of a maritime tort must be brought within 3 years after the cause of action arose." There are some exceptions to this, primarily with regard to Jones Act cases filed against the government, in which case the statute of limitations can be less than 2 years.[46]

State laws
State Misdemeanor Felony Notes
Michigan 6 years Murder: none; kidnapping, extortion, assault with intent or conspiracy to murder: 10 yrs.; others: 6 yrs.; if victim was under age 18 for any degree of sexual conduct or assault with intent to commit sexual conduct or any sexually abusive activity or material to minor: 10 yrs. or when the victim turns 21 yrs. old, whichever is later; if DNA evidence obtained: none until offender identified, then 10 yrs. after identification or when victim turns 21, whichever is later. Statute of Limitation tolls if defendant is not a resident and did not usually and publicly reside in the state. See MCL 767.24
North Carolina 2 years none No statute of limitations for "malicious misdemeanors", per NCGS §15-1
Wyoming No No No statute of limitations
Connecticut 1 year[47] Terrorism resulting in death: 55 yrs; Murder involving rape, cannibalism, or a child: 50 yrs; Mass Murder: 45 yrs; Murder: 40 yrs; Terrorism not resulting in death: 30 yrs; Manslaughter: 25 yrs; Rape: 15 yrs; Violent felonies: 10 yrs; Nonviolent felonies: 5 yrs; Nonviolent felonies committed by a minor: 2 yrs.[47] A bill was proposed to abolish the statute of limitations for most sex offenses, but it was not submitted for a vote in the state senate. Efforts continue to pass legislation to extend the limitations period for the prosecution of sex offenses.[48]

Exceptions

U.S. jurisdictions recognize exceptions to statutes of limitation that may allow for the prosecution of a crime or civil lawsuit even after the statute of limitations would otherwise have expired. Some states stop the clock for a suspect who is not residing within the state or is purposely hiding. Kentucky, North Carolina, and South Carolina have no statutes of limitation for felonies, while Wyoming includes misdemeanors as well. However, the right to speedy trial may derail any prosecution after many years have passed.[49]

Fraud upon the court

When an officer of the court is found to have fraudulently presented facts to impair the court's impartial performance of its legal task, the act (known as fraud upon the court) is not subject to a statute of limitation.[50][51] This mainly covers a "fraud where the court or a member is corrupted or influenced or influence is attempted or where the judge has not performed his judicial function — thus where the impartial functions of the court have been directly corrupted."[52] In this regard, the U.S. Court of Appeals for the Third Circuit has stated the following:

In order to meet the necessarily demanding standard for proof of fraud upon the court we conclude that there must be: (1) an intentional fraud; (2) by an officer of the court; (3) which is directed at the court itself; and (4) in fact deceives the court.[51]

Officer of the court in general includes any judge, law clerk, court clerk, lawyer, investigator, probation officer, referee, legal guardian, parenting-time expeditor, mediator, evaluator, administrator, special appointee, and/or anyone else whose influence is part of the judicial mechanism.[53]

Continuing-violations doctrine

In tort law, if any person or entity commits a series of illegal acts against another person or entity (or in criminal law if a defendant commits a continuing crime) the limitation period may begin to run from the last act in the series.[54] The entire chain of events can be tolled if the violations were continuing. The Court of Appeals for the Eighth Circuit has explained that the continuing-violations doctrine "tolls the statute of limitations in situations where a continuing pattern forms due to discriminatory acts occurring over a period of time, as long as at least one incident of discrimination occurred within the limitations period."[55] Whether the continuing-violations doctrine applies to a particular violation is subject to judicial discretion; it was said to apply to copyright infringement in the jurisdiction of the Seventh Circuit,[56] but not in the jurisdiction of the Second Circuit.[57][58]

gollark: Maybe it could be done with some detachable component to do the launch in the air if I was better at docking.
gollark: On Minmus I just gave it some long landing legs.
gollark: It would probably recoil itself against the ground.
gollark: Given the low gravity it would be safe, if annoying, to just raise it a bit during the launch. Except possibly the mass driver recoil would cause problems.
gollark: I suppose, just adding more reaction wheels and RCS to it would have worked.

See also

References
  1. "Statute of Limitations". California Court Judicial Branch. Public Access Records. Retrieved 6 June 2014.
  2. 18 U.S.C. § 249(d) ("Statute of Limitations")
  3. Special Historic Session. "Opening Remarks:HistoricSpecial section" (PDF). www.courts.ca.gov. Supreme Court Of California. Retrieved 6 June 2014.
  4. California Courts, Judicial Council. "Public Access Records". California Courts. Rewriting Amendments. Retrieved 6 June 2014.
  5. "Statute of Limitations by State for Civil Cases". ExpertLaw.com. ExpertLaw. Retrieved 4 May 2017.
  6. "State Statutes of Limitations". FindLaw. Thomson Reuters. Retrieved 4 May 2017.
  7. Halsbury's Laws of England, 4th edition
  8. Allen, Danielle S. (2003). The World of Prometheus: The Politics of Punishing in Democratic Athens. Princeton University Press. p. 154. ISBN 978-0-691-09489-2.
  9. "Statutes of Repose for Construction" (PDF). SDVLaw.com. Saxe Doernberger & Vita, P.C. Retrieved 4 May 2017.
  10. "MCL 600.5839". Michigan Legislature. State of Michigan. Retrieved 4 May 2017.
  11. "Cal. Civ. Proc. Code § 337.15". California Legislative Information. State of California. Retrieved 4 May 2017.
  12. "Fla. Stat. § 95.11(3)(c)". Online Sunshine. State of Florida. Retrieved 4 May 2017.
  13. Gabelli v. Securities and Exchange Commission.
  14. Macy J. (2013). Opinion analysis: That which does not kill the SEC may make the agency stronger. SCOTUSblog.
  15. "La prescrizione del reato dopo la ex-Cirielli". Diritto Penale. Retrieved 5 June 2013.
  16. "Codul Penal, Articolul 180 – Prescripția". Retrieved 9 October 2013.
  17. Ridley, Yvonne (2012-05-12). "Bush Convicted of War Crimes in Absentia". www.foreignpolicyjournal.com. Foreign Policy Journal. Retrieved 12 October 2014.
  18. Kohout, David, Statutory Limitation of Crimes under International Law: Lessons Taken from the Prosecution of Nazi Criminals in Germany after 1945 and the New Demjanjuk Case Law, International Comparative Jurisprudence, Vol. 3, Issue 1 (2017), pp. 37-54.
  19. "Parliamentary Inquiry On The Handling Of Child Abuse By Religious And Other Non-Government Organisations" (PDF). Parliament of Victoria. Retrieved 2014-07-31.
  20. "Parliament of Victoria". Inquiry Into The Handling of Child Abuse by Religious and Other Organizations. Retrieved 9 May 2013.
  21. "Victoria ends statutory time limit on historical child sex abuse cases". www.theaustralian.com.au. Australian Associated Press. Retrieved 12 October 2014.
  22. "Inquiry Into the Handling of Child Abuse by Religious and Other Organisations" (PDF). Parliament of Victoria. Retrieved 2014-07-31.
  23. "Waller Legal response" (PDF). Parliament of Victoria. Retrieved 2014-07-31.
  24. "A Submission by Care Leavers Australia Network (CLAN) to the Inquiry into the handling of child abuse by religious and other organisations" (PDF). Parliament of Victoria. Retrieved 2014-07-31.
  25. "Broken Rites response" (PDF). Parliament of Victoria. Retrieved 2014-07-31.
  26. "Inquiry Into the Processes by Which Religious and Other Non-government Organisations Respond to the Criminal Abuse of Children by Personnel Within Their Organisations" (PDF). Parliament of Victoria. Retrieved 2014-07-31.
  27. "Criminal Code". Section 46: Government of Canada. 2018-09-19. Retrieved 16 July 2015.CS1 maint: location (link)
  28. "Criminal Procedure". The Canadian Encyclopedia. Retrieved September 1, 2019.
  29. Judge sentences 80-year-old woman to 1 year in prison for sex crimes, CTV News, 10 February 2020.
  30. Un homme de 94 ans évite la prison pour des viols commis il y a 50 ans, Le Quotidien, 6 September 2019.
  31. Quebec actor Edgar Fruitier guilty of indecent assaults committed in the '70s Montreal Gazette, 22 July 2020.
  32. "Limitation Periods in Canada's Provinces and Territories" (PDF). fenninsurance.com. Olga Gil Research Services. Archived from the original (PDF) on 4 March 2016. Retrieved 30 October 2008.
  33. "Limitations Act, 2002, S.O. 2002, c. 24, Sched. B". E-laws.gov.on.ca. 2014-07-24. Retrieved 2014-07-31.
  34. "GERMAN CRIMINAL CODE". www.gesetze-im-internet.de. Retrieved 2018-08-03.
  35. "Microsoft Word - LIMITATION ACT" (PDF). Retrieved 2019-08-05.
  36. "Stortinget fjerner foreldelsesfristen" (in Norwegian). Dagsavisen. 2014-06-16. Retrieved 2017-06-05.
  37. "Stogner v. California". oyez.org. Retrieved 2007-12-30.
  38. Doyle, Charles (14 November 2017). "Statute of Limitation in Federal Criminal Cases: An Overview" (PDF). Congressional Research Service. Retrieved 18 March 2018.
  39. Larson, Aaron (27 February 2018). "Time Limits for Criminal Charges: What's the Statute of Limitations". ExpertLaw. Retrieved 18 March 2018.
  40. Grossman, Jonathan (2014). "Speedy Trial and the Statute of Limitations" (PDF). Sixth District Appellate Program. Retrieved 6 December 2017.
  41. Ullmer, Frank B. (2001). "Using DNA Profiles to Obtain John Doe Arrest Warrants and Indictments". Washington & Lee Law Review. 58: 1585. Retrieved 6 December 2017.
  42. Denson, Bryan (November 24, 1996). D.B. Cooper legend lives. Oregon Live archive Retrieved March 6, 2011.
  43. "Sixth Amendment - Limited Protection Against Excessive Prosecutorial Delay". Northwestern University School of Law. The Journal of Criminal Law and Criminology. Retrieved 12 October 2014.
  44. "Stogner v. California". Oyez. Chicago-Kent College of Law.
  45. "Airman who went missing in 1977 found living double life in Florida". Fox News. 17 October 2017.
  46. "33 U.S. Code § 913 - Filing of claims". Legal Information Institute. Cornell Law School. Retrieved 31 December 2018.
  47. Reinhart, Christopher (6 March 2015). "Statute of Limitations for Prosecutions" (PDF). Office of Legislative Research Research Report. State of Connecticut. Retrieved 22 May 2020.
  48. Krasselt, Kaitlyn (20 February 2020). "Legislature unlikely to eliminate civil statute of limitations for sex abuse". Connecticut Post. Retrieved 22 May 2020.
  49. "Criminal Statutes of Limitations for All 50 States". resources.lawinfo.com.
  50. Kenner v. C.I.R., 387 F.2d 689, 691 (7th Cir. 1968).
  51. Herring v. United States, 424 F.3d 384, 386-87 (3d Cir. 2005); see also, generally 18 U.S.C. § 242 ("Deprivation of rights under color of law"); 18 U.S.C. § 371 ("Conspiracy to commit offense or to defraud United States"); 18 U.S.C. § 1001(a) ("Statements or entries generally").
  52. Bulloch v. United States, 763 F.2d 1115, 1121 (10th Cir. 1985).
  53. "Deprivation Of Rights Under Color Of Law". U.S. Department of Justice (DOJ). August 6, 2015. Retrieved 2019-01-23.
  54. "Continuing Violation Doctrine Law and Legal Definition". definitions.uslegal.com. Retrieved 2019-01-24. See also Egervary v. Young, 366 F.3d 238, 246 (3d Cir. 2004) ("Traditionally, in tort law, 'proximate cause' has been defined as a person's wrongful conduct which is a substantial factor in bringing about harm to another.").
  55. Treanor v. MCI Telecommunication Corp., 200 F.3d 570, 573 (8th Cir. 2000)
  56. Taylor v. Meirick, 712 F.2d 1112, 1119 (7th Cir. 1983)
  57. Stone v. Williams, 970 F.2d 1043, 1049–50 (2d Cir. 1992).
  58. "Archived copy" (PDF). Archived from the original (PDF) on 2012-01-18. Retrieved 2011-08-13.CS1 maint: archived copy as title (link)
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