RESPONDENT: Chicago Police Officers Kristen Kato and Eugene Roy
LOCATION: United States District Court for the District of Colorado
DOCKET NO.: 05-1240
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: United States Court of Appeals for the Seventh Circuit
CITATION: 549 US 384 (2007)
GRANTED: Jun 19, 2006
ARGUED: Nov 06, 2006
DECIDED: Feb 21, 2007
Benna Ruth Solomon - argued the cause for Respondents
Kenneth N. Flaxman - argued the cause for Petitioner
Facts of the case
In 1994, Andre Wallace was arrested and charged with murder. Two years later he was convicted and sent to prison. Wallace appealed, arguing that the police had arrested him without probable cause and coerced him into confessing to the crime. In 1998, an appeals court agreed that Wallace had been arrested without probable cause and granted him a new trial. Finally, in 2002, the prosecution dropped its case against him. The next year Wallace sued the police officers and the city of Chicago for violating his Fourth Amendment rights through false arrest.
The District Court ruled against Wallace, because his suit was time-barred. In Illinois there is a two-year statute of limitations on false-arrest claims. Since Wallace had not brought suit within two years of either his arrest or the time the arrest was declared invalid, his time was up. Wallace appealed to the Seventh Circuit Court of Appeals, arguing that the two-year limit did not begin until his conviction was finally set aside in 2002.
The Circuit Court upheld the District Court, ruling against Wallace. The Circuit Court panel acknowledged that other Circuits had failed to agree on the question of when the statute of limitations for a false arrest claim should begin. The Seventh Circuit opted for a clear rule - the two-year limit starts at the time of the arrest, and therefore Wallace's suit was too late
When does the statute of limitations for a claim for damages arising out of a false arrest start running when the fruits of the search were introduced in a person's criminal trial and he was convicted?
Media for Wallace v. KatoAudio Transcription for Oral Argument - November 06, 2006 in Wallace v. Kato
Audio Transcription for Opinion Announcement - February 21, 2007 in Wallace v. Kato
John G. Roberts, Jr.:
Justice Scalia has the opinion this morning in No. 05-1240, Wallace versus Kato.
Now this case is here on writ of certiorari to the United States Court of Appeals for the Seventh Circuit.
On January 17, 1994 John Handy was shot and killed in the city of Chicago.
Two days later Chicago police officers, the respondents here, arrested petitioner who was then 15 years of age.
After several hours of interrogation petitioner confess to the murder.
He was tried and convicted but in 2001 a State Court vacated his conviction after concluding that his confession was inadmissible as the product of an arrest that violated the Fourth Amendment.
The state did not thereafter retry petitioner and instead dropped the charges in April of 2002.
In April of 2003, petitioner filed this civil rights suit under 42 U.S.C. § 1983 seeking damages arising from his unlawful arrest which had taken placed nearly ten years earlier.
The District Court granted summary judgment to respondents, the police officers who had made the arrest and the Court of Appeals affirmed.
According to the Seventh Circuit petitioner’s 1983 suit was time-barred because of the clock on his statute of limitations began to run at the time of his arrest and not many years later when his conviction was eventually set aside.
We granted certiorari and now affirmed.
Section 1983 is a federal clause of action.
But it occasionally borrows from the law of the state in which the cause of action arose.
That is so for the length of the statute of limitations which we have held is the limitations period that the state provides for personal injury suits, here under Illinois law two years.
The accrual date of 1983 clause of action that is when the clock begins to run is a question of federal law resolved not by reference to state law but by federal rules conforming in general to common law toward principles.
Under those principles a claim accrues when the plaintiff has a complete and present clause of action entitling him to file suit and obtain relief.
In this case petitioner suffered an injury immediately upon his unlawful arrest and could have filed suit at that time.
The statute of limitations would thus normally commence to run from that day.
But we have to refine this analysis because of a common law’s distinctive treatment of it towards a false imprisonment and its subspecies false arrest.
The causes of action that provide the closest analogy to claims of the type considered here.
False imprisonment is the proper analogy because it remedies detention without legal process and the allegations before us arise from respondent’s detention of petitioner without warrant in January of 1994.
They didn’t have a warrant or any other valid cause according to the decisions below to detain him.
Under common law the running of the statue limitations on false imprisonment is subject to a distinctive rule.
The limitation begins to run against an action for false imprisonment when the alleged false imprisonment ends.
The reason for that role is obvious you can hardly file a suit while you’re still being imprisoned.
When then did petitioner’s false imprisonment end?
Reflecting the fact that false imprisonment consists of detention without legal process.
A false imprisonment ends once the victim becomes held pursuant to such process, when for example he is bound over by a magistrate or arraigned on charges.
Thus petitioner’s false imprisonment did not end when as he says the state dropped its charges but rather when petitioner appeared before the examining magistrate and was bound over for trial.
Since more than two years elapsed between that date and the filing of this suit even leaving out of the count the period when petitioner was still a minor his action was time-barred.