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.