McGroarty v. Swearingen, No. 19–10537 (11th Cir. 2020)
Nature of Case: Appellant was convicted in the early 00’s of a sex offense in Florida and was sentenced to ten years’ probation and required to register. Appellant thereafter left Florida and completed his probation, but the Florida Department of Law Enforcement still displayed his registration information on their public website — his lack of connection with the state notwithstanding. Appellant filed a civil rights lawsuit alleging that this practice violated his substantive Due Process rights. The state sought to dismiss the lawsuit, on the grounds that it was barred by the applicable statute of limitations. The trial court dismissed the lawsuit, and Appellant sought review.
Holding: The 11th Circuit Court of Appeals affirmed the trial court, finding that the applicable statute of limitations began to run either in 2004 or 2012, and that there was no continuing violation that would otherwise toll the statute of limitations period.