Custer v. McCutcheon

In Custer v. McCutcheon, 283 U.S. 514, 75 L. Ed. 1239, 51 S. Ct. 530 (1931), the United States Supreme Court interpreted a federal law providing that a party recovering a judgment in district court was entitled to the same remedies as provided for by the laws of the state in which the court was held. 283 U.S. at 515-16. Idaho law imposed a five-year limitation on the execution of a judgment. Id. at 515. The Supreme Court held that the United States, like any other plaintiff, was required under Idaho law to execute a judgment within five years. Id. at 519. The Court concluded that the time limit for executing a judgment was not "strictly speaking" a statute of limitations, and that "in the interest of uniformity in the mode of proceedings in state and federal courts, and in the absence of either express state decision or provision by Congress to the contrary, the statute is to be held applicable to all plaintiffs." Id.