Kino Bonelli v. Grand Canyon University, 28 F.4th 948

In February 2017 Bonelli (a Black student) was denied campus entry and had his student ID taken during an encounter with GCU campus police; he alleges Fourth and First Amendment injuries and racial discrimination.
On July 25, 2017, another campus encounter led to a BOLO describing Bonelli with false information; the BOLO was withdrawn about a week later.
GCU issued an Official Disciplinary Warning to Bonelli on August 24, 2017 threatening further sanctions; Bonelli later obtained an internal review and the warning was rescinded on August 29, 2018.
Bonelli filed suit on January 20, 2020 asserting § 1983 claims (Fourth Amendment seizure/detention; First Amendment retaliation) and racial-discrimination claims under §§ 1981 and 2000d.
The district court dismissed the complaint with prejudice as time-barred under Arizona’s two-year limitations period; Bonelli appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When do Bonelli’s federal civil‑rights claims accrue?	Accrual should be delayed until the disciplinary warning was rescinded (Aug 29, 2018).	Claims accrued when plaintiff knew or should have known of the injury (when incidents occurred).	Accrual follows federal rule: plaintiff knew of injuries in Feb and July 2017; claims accrued then.
Does Heck v. Humphrey defer accrual until favorable termination of disciplinary action?	Heck’s delayed‑accrual principle applies so claims did not accrue until GCU withdrew the warning.	Heck applies only to criminal convictions/sentences; not to university disciplinary warnings.	Heck does not apply; there was no conviction or sentence to be undermined.
Can a Heck‑like malicious‑prosecution accrual rule be analogized to university discipline to delay accrual?	A favorable‑termination requirement should apply by analogy to malicious prosecution.	Malicious‑prosecution analogy is inapt; core policy reasons for favorable‑termination (e.g., avoiding collateral attack on criminal judgments) are absent.	Court rejects analogous rule; plaintiff’s claims were independent injuries and accrued when they occurred.
Were the claims timely filed?	Filing within two years of rescission would be timely under plaintiff’s theory.	Under controlling accrual law, suit filed >2 years after accrual and is untimely.	Held untimely; district court dismissal affirmed.

Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (§ 1983 claims that would imply invalidity of conviction/sentence are barred until conviction is invalidated)
Wallace v. Kato, 549 U.S. 384 (U.S. 2007) (accrual of § 1983 claims governed by federal law; accrual when plaintiff knows of injury)
Muhammad v. Close, 540 U.S. 749 (U.S. 2004) (Heck inapplicable where disciplinary proceedings do not affect conviction or sentence)
McDonough v. Smith, 139 S. Ct. 2149 (U.S. 2019) (explaining favorable‑termination requirement and its justifications for malicious prosecution‑type claims)
Lukovsky v. City & County of San Francisco, 535 F.3d 1044 (9th Cir. 2008) (federal accrual rule: claim accrues when plaintiff knows or should know of injury)
Belanus v. Clark, 796 F.3d 1021 (9th Cir. 2015) (Fourth Amendment seizures accrue at the time of the wrongful act)
Pouncil v. Tilton, 704 F.3d 568 (9th Cir. 2012) (claim accrues when plaintiff has a complete and present cause of action)