Appeal from the United States District Court for the Middle District of Tennessee at Nashville.
No. 3:22-cv-00896—Aleta Arthur Trauger, District Judge.
Decided and Filed: July 31, 2024
Before: GIBBONS, WHITE, and MURPHY, Circuit Judges.
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OPINION
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PER CURIAM. In January 2019, Detective Lori Russ searched Connie Reguli’s private
Facebook records allegedly because Russ disliked Reguli’s criticism of the police. Reguli
learned of this search a year later when preparing for her criminal trial. She did not sue over the
search at that time. Much later, however, Reguli learned that her speech had motivated the
search when Russ seemed to admit as much at Reguli’s sentencing in July 2022.
That November, Reguli filed a First Amendment retaliation claim against Russ and her employer
under 42 U.S.C. § 1983. But Reguli’s § 1983 claim triggered a short one-year statute of
limitations under Tennessee law. So the district court dismissed Reguli’s claim as untimely.
The court reasoned that this claim had accrued when Reguli learned of Russ’s search—not when
she learned of Russ’s motivation for it. We agree and affirm. |