If the statute of limitations is two years in PA for this type of action, it makes no difference if the it is a state or federal claim (statute of limitations for civil actions are determined by state law unless federal law makes an exception for a federal claim). For defamation cases, the state statute of limitations applies, even in federal court; Sharratt's case will be dismissed because it was not filed in a timely matter. END OF STORY.
Hmmmmmm. I don’t understand why this was filed in the first place if it was beyond the statute of limitations.