In Burnett et al. v. Grattan et al., the Supreme Court ruled on a statute of limitations issue related to civil rights claims under 42 U.S.C §1983, which provides recourse for deprivation of constitutional or federal statutory rights by persons acting under color of state law. The plaintiffs were teachers who alleged that their First Amendment rights had been violated when they were transferred from one school district to another in retaliation for their criticism of administrative policies. They filed suit more than three years after the transfer but within Maryland's general personal injury statute of limitations period, arguing that this should apply rather than a shorter limitation period specific to personnel actions against government officials. The Supreme Court disagreed and held that where state law provides multiple statutes of limitations for personal injury actions, courts considering §1983 claims should borrow the general or residual statute for personal injury actions (in this case, three years). However, it also clarified that if there is a closely analogous cause-of-action under state law with its own special rule regarding time limits (like personnel action), then such special rule will not be borrowed; instead only the most appropriate one would be applied.

In the dissenting opinion for Burnett et al. v. Grattan et al., Justice Stevens argued that the majority's decision to apply a federal statute of limitations rather than state law was inconsistent with precedent and undermined states' rights. He contended that Congress intended for state laws to govern civil rights claims unless they were "inconsistent with the Constitution and laws of the United States." In this case, he believed there was no such inconsistency, as Maryland’s three-year statute of limitations provided ample time for plaintiffs to file their claim. Furthermore, he expressed concern about potential confusion caused by applying different statutes depending on whether a claim is filed in federal or state court within the same jurisdiction. Lastly, Justice Stevens disagreed with imposing an absolute rule requiring immediate filing upon discovery of injury; instead advocating flexibility based on individual circumstances.