Hubert Martin v. Lisa Julian, 18 F.4th 580

Background

On November 7, 2011, law enforcement executed a warrant on Hubert Martin’s property, arresting Hubert Martin, Karen Farmer, and Matthew Williams and seizing property (including guns and vehicles) in a methamphetamine investigation.
In January 2016 the State nolle prossed the criminal charges after deposition testimony from Dustin Miller that Deputy Blake Hudson recruited Miller to plant drug-making components and a “smoker bottle” on Martin’s property in exchange for assistance in a custody dispute.
Plaintiffs filed a § 1983 suit in December 2018 against Hudson and three task-force agents, alleging fabricated evidence, unlawful search and seizure, false imprisonment, Brady violations, and state malicious-prosecution/false-imprisonment claims.
The district court dismissed the complaint (plaintiffs had not responded to motions to dismiss), holding the Fourth Amendment claims time-barred under Arkansas’s three-year statute of limitations and rejecting the Brady claim; it declined supplemental jurisdiction over state claims.
Plaintiffs moved to vacate the dismissal arguing the court overlooked a § 1983 malicious-prosecution claim; the district court denied relief. The plaintiffs appealed.
The Eighth Circuit affirmed, holding the federal claims time-barred and that plaintiffs failed to state a plausible § 1983 malicious-prosecution claim under controlling precedent.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of § 1983 unlawful search/seizure and false imprisonment claims	Claims accrued later (continuing injury) and were timely because charges were nolle prossed in 2016	Accrual occurred in late 2011 at seizure/arrests/process; Arkansas 3‑year statute bars suit filed in 2018	Accrual is federal-law question: seizure accrues at seizure; false imprisonment accrues at issuance of process; claims time‑barred
Viability and timeliness of § 1983 malicious prosecution claim	Malicious-prosecution claim accrues at favorable termination (2016) and thus is timely	Plaintiffs did not plead a standalone § 1983 malicious-prosecution claim and alleged constitutional violations occurred before process and are time‑barred	Eighth Circuit: plaintiffs failed to state a plausible § 1983 malicious-prosecution claim under circuit precedent; court did not abuse discretion in denial of vacatur
Brady / due-process claim for nondisclosure of informant recruitment	Plaintiffs alleged nondisclosure of Miller’s recruitment violated due process	Defendants: Brady applies in the context of criminal prosecutions and convictions; court previously found Brady claim insufficient	Plaintiffs do not contest dismissal on appeal; district court’s dismissal of Brady claim affirmed
Denial of motion to vacate / set aside dismissal (Rule 52/60) and standard used	Plaintiffs argued court overlooked malicious-prosecution claim and misapplied standards	Defendants supported dismissal for failure to state claim and timeliness; court properly treated the filings and applied Rule 12(b)(6) standards	Court did not abuse its discretion; it permissibly construed filings and correctly applied Rule 12(b)(6) standards

Key Cases Cited

Wilson v. Garcia, 471 U.S. 261 (U.S. 1985) (§ 1983 claims borrow state statute of limitations)
Wallace v. Kato, 549 U.S. 384 (U.S. 2007) (accrual rules for false imprisonment and malicious prosecution principles)
Manuel v. City of Joliet, 137 S. Ct. 911 (U.S. 2017) (malicious-prosecution accrual tied to favorable termination)
McDonough v. Smith, 139 S. Ct. 2149 (U.S. 2019) (fabricated-evidence claims and statute-of-limitations considerations)
Joseph v. Allen, 712 F.3d 1222 (8th Cir. 2013) (malicious-prosecution allegations alone do not sustain a § 1983 claim)
Kaster v. Iowa, 975 F.2d 1381 (8th Cir. 1992) (unlawful seizure accrual at time of seizure)
Miller v. Norris, 247 F.3d 736 (8th Cir. 2001) (Arkansas limitations period applies to § 1983 actions)
Livers v. Schenck, 700 F.3d 340 (8th Cir. 2012) (Brady-related due process principles relied on below)