Supreme Court Highlights Re: Statute Of Limitations In False Arrest Claims

Here are some highlights from the United States Supreme Court's opinion in Andrew Wallace v. Kato, et al regarding the statute of limitations in false arrest claims. First, the court noted that "[w]hile we have never stated so expressly, the accrual date of a 1983 cause of action is a question of federal law that is not resolved by reference to state law."  Second, the court stated that "limitations begin to run against an action for false imprisonment when the alleged false imprisonment ends." Third, the court held that "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." In the case of Andre Wallace, the Supreme Court concluded that "the statute of limitations on petitioner's 1983 claim commenced to run when he appeared before the examining magistrate and was bound over for trial." Since more than two years (Illinois statute of limitations for personal injury torts) had elapsed between the date when Wallace appeared before the magistrate and was bound over for trial and the filing of his suit, his action was time-barred.

US Supreme Court Affirms Wallace v. Kato Ruling

The United States Supreme Court has affirmed the Seventh Circuit's holding in Wallace v. Kato, et al. The Supreme Court, in an opinion authored by Justice Scalia, held that the statute of limitations upon a section 1983 claim seeking damages for false arrest in violation of the Fourth Amendment, where the arrest is followed by criminal proceedings, begins to run at the time the claimant becomes detained pursuant to to legal process. As background, in January 1994, the Chicago police arrested Wallace for murder. He was tried and convicted, but the charges were later dropped in April 2002. In April 2003, Wallace filed suit under section 1983 against the City of Chicago and several police offices , seeking damages for, among other things, his alleged unlawful arrest in violation of the Fourth Amendment. The District Court granted summary judgment and the Seventh Circuit affirmed, ruling that the section 1983 suit was time barred because Wallace's cause of action accrued at the time of his arrest,  not when his conviction was later set aside. In a written opinion dated February 21, 2007, the United States Supreme Court affirmed the Seventh Circuit's ruling. The case was argued before the Supreme Court by Benna Ruth Solomon on behalf of the City of Chicago.