The case McDonough v. Smith involved a dispute over the statute of limitations for civil rights claims related to fabricated evidence in a criminal proceeding. Edward McDonough, former Democratic Commissioner of Rensselaer County Board of Elections, was indicted based on allegedly forged absentee ballots but was acquitted after two trials. He then filed a lawsuit against Youel Smith who had acted as special prosecutor during his trial, accusing him of fabricating evidence and violating his due process rights. The key issue before the Supreme Court was when does the three-year statute of limitations start for such lawsuits: from the date when defendant first becomes aware that false evidence has been used against them or from the end date of legal proceedings where this false evidence has been presented? The Supreme Court ruled in favor of McDonough stating that "the statute-of-limitations clock for a Section 1983 fabrication-of-evidence claim begins to run when legal proceedings have terminated in favor of the accused." This decision allows individuals more time to file lawsuits if they believe their civil rights were violated through use or creation by law enforcement officials.

In the dissenting opinion for McDonough v. Smith, Justice Sotomayor argued that the majority's interpretation of when a §1983 claim accrues is too narrow and inconsistent with precedent. She contended that a claim should be considered to have accrued once the plaintiff knows or has reason to know of his injury, regardless of whether he can yet sue under §1983. According to her view, this approach would better align with Congress’s intent in enacting §1983 - providing a federal remedy for violations of constitutional rights - by ensuring claims are not prematurely cut off before they can even be brought. Furthermore, she expressed concern about how the majority's decision could potentially limit access to justice for victims who may not realize their rights were violated until after limitations period had expired.