Reaffirmation of the Rebuttable Presumption of Receipt in §1983 Claim Accrual: The Mailbox Rule Upheld in Katergaris v. City of New York

Introduction

In Katergaris v. City of New York (2d Cir. Apr. 15, 2025), Serafim Georgios Katergaris sued the City of New York under 42 U.S.C. § 1983, alleging a due process violation in connection with fines assessed by the Department of Buildings (“DOB”). The core dispute concerned when Katergaris’s claim accrued for statute‐of‐limitations purposes: did it accrue when the City mailed him a notice of violation in March 2015 or when he first learned of the violation in 2021? The District Court granted summary judgment for the City, finding that properly mailed notices give rise to a rebuttable presumption of receipt which Katergaris failed to overthrow. The Second Circuit affirmed, thereby reaffirming the federal “mailbox rule” presumption in § 1983 accrual contexts.

Summary of the Judgment

The Court of Appeals affirmed the District Court’s grant of summary judgment. It held that:

A three‐year statute of limitations applies to § 1983 claims under New York law.
Under federal law, a claim accrues when a plaintiff “knows or has reason to know of the injury.”
Testimony and records showing that the DOB and its contractor properly addressed and mailed the March 2015 violation notice give rise to a rebuttable presumption that Katergaris received it.
Katergaris’s denial of receipt and circumstantial evidence regarding his unreliable mail retrieval system were insufficient to rebut the presumption.
Consequently, his cause of action accrued in March 2015, and his 2022 lawsuit was time‐barred.

Analysis

Precedents Cited

The Second Circuit carefully traced and applied established precedents:

Shomo v. City of New York (579 F.3d 176): Adopted New York’s three‐year limitations period for § 1983.
Barnes v. City of New York (68 F.4th 123): Confirmed that accrual occurs when a plaintiff knows or should know of the injury.
Akey v. Clinton County (375 F.3d 231): Held that evidence of proper mailing according to office procedures creates a presumption of receipt.
Ma v. Merrill Lynch (597 F.3d 84): Clarified that testimonial proof of regular mailing processes establishes prima facie mailing evidence.
Meckel v. Continental Resources (758 F.2d 811): Defined the rebuttable presumption and noted that direct proof of procedural failure is not the only way to rebut.
Silva-Carvalho Lopes v. Mukasey (517 F.3d 156): Discussed mailing presumptions in immigration contexts but reaffirmed the general approach.
United States v. Barrett (102 F.4th 60): Rejected challenges to the mailbox rule under Rule 301 and endorsed its continued application.
ITC Ltd. v. Punchgini (482 F.3d 135): Emphasized that mere allegations of state of mind cannot defeat summary judgment.

Legal Reasoning

The court’s reasoning unfolded in three steps:

Applicability of the Mailbox Rule: When an administrative agency mails a notice in the ordinary course of business, the recipient is presumed to have received it. This presumption shifts the burden to the recipient to show non‐receipt.
Establishment of the Presumption: The City introduced testimony from DOB manager Juan Ruiz and Vanguard employee Michael Muniz describing the chain of custody—from compiling violation lists to mailing—sufficient under Ma and Meckel.
Rebuttal Analysis: Katergaris offered only (a) his own declaration of non‐receipt, (b) evidence that he normally addressed citations promptly, and (c) testimony that his mailbox system was unreliable. Under Akey and Meckel, denial alone, even with circumstantial mail‐retrieval issues, fails to rebut the presumption.

Having confirmed that the notice was mailed and the presumption unrebutted, the court concluded accrual occurred in March 2015 and affirmed summary judgment.

Impact

This decision carries significant implications:

It cements the mailbox rule in § 1983 contexts, ensuring that properly mailed administrative notices trigger accrual and the running of limitations.
It places the onus on plaintiffs to produce meaningful evidence of mailing irregularities or misdelivery, rather than relying on denials alone.
It promotes procedural uniformity across federal and administrative cases, deterring strategic delay in discovering claims.
It signals that challenges to mailing presumptions under Federal Rule of Evidence 301 will face a high bar in the Second Circuit.

Complex Concepts Simplified

Accrual Date: The date when a plaintiff “knows or has reason to know” of the injury—here, when notice of the boiler‐inspection fine was deemed received.
Mailbox Rule (Presumption of Receipt): A legal assumption that mail properly addressed and mailed in the usual course of business is received by its addressee.
Rebuttable Presumption: A presumption that stands unless the opposing party introduces evidence sufficient to raise doubt.
Section 1983 Claim: A civil action for deprivation of constitutional rights by persons acting under color of state law.
Summary Judgment: A procedural device resolving cases when no genuine dispute of material fact exists.
Federal Rule of Evidence 301: Governs presumptions in civil cases, but does not override well‐established mailbox doctrines in this Circuit.

Conclusion

Katergaris v. City of New York reaffirms that in the § 1983 context, a properly mailed administrative notice creates a strong, rebuttable presumption of receipt—triggering accrual of the claim. Denials of receipt and generalized evidence of an unreliable mailbox are insufficient to overcome the presumption. By affirming the traditional mailbox rule, the Second Circuit reinforces predictability in limitation periods and underscores the importance of timely challenge to administrative actions.