876 F.3d 939
7th Cir.2017Background
- Milan Brown was sentenced July 19, 2013 to 300 days for a probation violation; the state circuit court stated he should be released in September 2013 after good-time credit.
- Cook County Jail staff did not release Brown in September; he remained detained until a habeas hearing on December 16, 2013, when the state court found he should have been released earlier and freed him on bond.
- The state court formally discharged the bond on January 17, 2014.
- Brown filed a § 1983 suit on December 30, 2015 against Sheriff Thomas Dart and Cook County for false imprisonment (Fourth Amendment) and inhumane conditions (Eighth Amendment), and an Illinois false-imprisonment claim.
- Defendants moved for judgment on the pleadings, arguing the § 1983 claims were time-barred; the district court granted judgment for defendants, and Brown appealed only the § 1983 false-imprisonment timeliness ruling.
- The Seventh Circuit reviewed de novo and accepted Brown’s well-pleaded facts but affirmed that Brown’s § 1983 false-imprisonment claim accrued on December 16, 2013 and was filed after the two-year Illinois limitations period.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| When did § 1983 false-imprisonment claim accrue? | Accrual should be Jan 17, 2014 (when bond was released) | Accrual on Dec 16, 2013 (date court released him from jail) | Accrual on Dec 16, 2013; claim filed >2 years later and is time-barred |
| Whether post-release bond restrictions continue the false imprisonment or delay accrual | Time on bond was a continuation of confinement (travel and firearm restrictions) | Bond conditions were court-imposed legal process, not unconstitutional detention by sheriff/county | Bond restrictions do not continue the false imprisonment; accrual not delayed |
| Whether Heck v. Humphrey required waiting for resentencing before filing § 1983 claim | Brown contended he had to wait until resentencing (Jan 17, 2014) | Heck inapplicable because Brown does not seek invalidation of sentence | Heck does not apply; claim could accrue before resentencing |
Key Cases Cited
- Wallace v. Kato, 549 U.S. 384 (statute of limitations for false imprisonment begins when imprisonment ends)
- Heck v. Humphrey, 512 U.S. 477 (claim that would imply invalidity of conviction or sentence is barred until sentence is invalidated)
- Hayes v. City of Chicago, 670 F.3d 810 (standard of review for judgment on the pleadings in § 1983 actions)
- Gekas v. Vasiliades, 814 F.3d 890 (Illinois two-year limitation governs § 1983 claims; accrual is federal question)
- Albright v. Oliver, 975 F.2d 343 (defining imprisonment narrowly for constitutional claims)