Wallace v. Kato
127 S. Ct. 1091, 549 U.S. 384 (2007)
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Rule of Law:
The statute of limitations for a § 1983 claim seeking damages for a false arrest in violation of the Fourth Amendment begins to run when the claimant becomes detained pursuant to legal process, such as after an arraignment or magistrate hearing, not when a subsequent conviction is overturned.
Facts:
- On January 17, 1994, John Handy was shot and killed in Chicago.
- Two days later, Chicago police located the 15-year-old petitioner, Andre Wallace, and transported him to a police station for questioning.
- Police interrogated Wallace into the early morning hours of the next day.
- Wallace agreed to confess to the murder, signed a prepared statement to that effect, and waived his Miranda rights.
- The police did not have a warrant for Wallace's arrest at the time they took him into custody.
Procedural Posture:
- Andre Wallace was tried for first-degree murder in the Circuit Court of Cook County, Illinois, a state trial court.
- The trial court denied Wallace's pre-trial motion to suppress his confession.
- A jury convicted Wallace, and he was sentenced to 26 years in prison.
- Wallace (appellant) appealed to the Appellate Court of Illinois, an intermediate appellate court.
- The Appellate Court held that police had arrested Wallace without probable cause and ultimately remanded for a new trial, concluding his statements were inadmissible.
- Following remand, state prosecutors dropped all charges against Wallace.
- Wallace (plaintiff) filed a § 1983 suit against the City of Chicago and its police officers (defendants) in the U.S. District Court.
- The District Court granted summary judgment to the defendants, finding the suit was time-barred.
- Wallace (appellant) appealed to the U.S. Court of Appeals for the Seventh Circuit, which affirmed the district court's judgment.
- The U.S. Supreme Court granted certiorari to review the Seventh Circuit's decision.
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Issue:
Does the statute of limitations for a § 1983 claim seeking damages for a false arrest begin to run when the false imprisonment ends, which occurs at the moment the individual becomes held pursuant to legal process, rather than when the individual's subsequent conviction is invalidated?
Opinions:
Majority - Justice Scalia
Yes. The statute of limitations for a § 1983 false arrest claim begins to run when the claimant is held pursuant to legal process. The accrual date for a § 1983 claim is determined by federal law, which looks to common-law tort principles. The closest common-law analogue to a Fourth Amendment unlawful arrest claim is the tort of false imprisonment, which remedies detention without legal process. This tort ends, and the limitations period begins to run, once the victim becomes held pursuant to legal process, such as being bound over by a magistrate. Detention after that point is covered by the distinct tort of malicious prosecution. The Court rejected the argument that the rule from Heck v. Humphrey should apply, as Heck's deferred accrual rule is only triggered when a lawsuit would impugn an existing conviction. Here, at the time the claim for false imprisonment accrued, no conviction existed. Extending Heck to anticipated future convictions would be impractical and speculative, so the standard accrual rule applies.
Concurring - Justice Stevens
Yes. The cause of action accrued once the Fourth Amendment violation was completed. The proper analysis rests not on common-law tort analogies, but on the relationship between § 1983 and the federal habeas corpus statute. The rule in Heck v. Humphrey, which can delay accrual, was designed to prevent § 1983 from being used to circumvent habeas corpus procedures. However, under Stone v. Powell, federal habeas relief is generally unavailable for Fourth Amendment claims if the state provided a full and fair opportunity to litigate them. Because a habeas remedy was never available to the petitioner for this claim, the Heck rule cannot apply to postpone the accrual of his § 1983 action.
Dissenting - Justice Breyer
No. While the accrual date is not postponed, the doctrine of equitable tolling should apply to pause the running of the statute of limitations until all related state criminal proceedings are completed. The majority's approach of requiring a plaintiff to file a lawsuit and then ask for a stay is impractical, forcing simultaneous litigation in civil and criminal courts and creating risks of inconsistent findings. Equitable tolling is a well-established tool for circumstances beyond a plaintiff's control, and it would provide for orderly adjudication, reduce unnecessary protective filings, and ensure that a meritorious § 1983 claim is not lost simply because the plaintiff was focused on challenging their unlawful confinement in the criminal system.
Analysis:
This decision clarifies the statute of limitations for one of the most common § 1983 claims, false arrest, establishing a clear but early start date. It significantly cabins the reach of Heck v. Humphrey, limiting its deferred accrual rule to claims that would invalidate an already existing conviction at the time the claim accrues. The practical impact is that individuals who are wrongly arrested and prosecuted must file their federal civil rights claims within the limitations period (typically two years) running from their initial court appearance, even if their criminal case is still pending. The prescribed remedy is to file the civil suit and then immediately ask the federal court for a stay pending the outcome of the criminal proceedings.
