In Sharkey v. O’Neal, 778 F.3d 767 (9th Cir. 2015), the Ninth Circuit held that the statute of limitations for claims under Title II of the Americans with Disabilities Act (public services disability discrimination), which does not contain an express statute of limitations, is the forum state’s statute of limitations for an analogous disability discrimination cause of action. The court held that the statute of limitations for a § 1983 claim does not apply if there is an analogous state law claim, and that the same statute-of-limitations period does not necessarily apply to all ADA claims, e.g., Title I (employment discrimination) or Title III (public accommodations disability discrimination). Rather, a court must apply the “most appropriate” or “most analogous” state statute of limitations. In this case, a California statute provided an “almost identical state-law counterpart to Title II,” and therefore the statute of limitations for that statutory claim (“an action upon a liability created by statute”) applied, not the statute of limitations for § 1983 claims.