Marcel Green v. Irvington Police Department, 24-3078

In February 2016, Marcel Green’s apartment was searched with a warrant, and police found numerous prescription drugs and allegedly forged prescriptions.
Green was arrested, but the 2016 charges were dismissed in 2018 due to issues with pill testing.
Green was arrested again in December 2018 following a continued investigation, and in November 2019, he pleaded guilty to drug possession under New Jersey law.
Green filed a pro se civil rights action under 42 U.S.C. § 1983 based on both arrests, alleging violations of his constitutional rights.
The District Court granted summary judgment to the defendants, finding Green’s 2016 claims time-barred and probable cause for his 2018 arrest.
Green appealed the summary judgment decision to the Third Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Statute of Limitations on 2016 Arrest	Claims not time-barred, warrant invalid	Claims expired under NJ’s two-year limitations period	Claims time-barred, filed after deadline
False Arrest for 2018 Arrest	No probable cause; lawful possession	Guilty plea; at least one valid basis for arrest	Probable cause established; no false arrest
Additional/Forfeited Claims	Addresses new issues in reply; other claims	Issues not briefed timely; some claims not argued	Forfeited/unaddressed claims not considered

Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard—genuine dispute of material fact)
Blunt v. Lower Merion Sch. Dist., 767 F.3d 247 (standard for plenary review of summary judgment)
Dique v. N.J. State Police, 603 F.3d 181 (statute of limitations for § 1983 claims in NJ)
Kach v. Hose, 589 F.3d 626 (accrual of claims under federal law)
James v. City of Wilkes-Barre, 700 F.3d 675 (elements for false arrest claim)
Startzell v. City of Phila., 533 F.3d 183 (probable cause on any charge defeats false arrest claim)