Matthew Beckstrand v. Thomas Read, 680 F. App'x 609

Plaintiff Matthew Beckstrand sued Thomas Read and Nettie Simmons under 42 U.S.C. § 1983, alleging they miscalculated his parole end date by refusing to honor credit for time served.
Beckstrand learned in October 2008 from Simmons that the Hawaii Department of Public Safety would not honor the claimed credit for time served.
Beckstrand filed suit against Read and Simmons on September 30, 2011 — more than two years after he discovered the alleged injury.
The district court granted summary judgment for Read and Simmons; the Ninth Circuit panel affirmed.
The court applied Hawaii’s two-year statute of limitations for personal injury claims to the § 1983 action and held federal law governs accrual (when plaintiff knew or should have known of the injury).
The panel also explained that, even absent the statute-of-limitations bar, Read and Simmons would be entitled to qualified immunity because they relied on Hawaii statute and controlling state precedent when calculating parole end dates.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Statute of limitations — accrual and timeliness	Beckstrand contends his § 1983 claim was timely (implied: accrual later or tolling).	Defendants argue Hawaii’s two-year limit applies and claim accrued when Beckstrand was told in Oct 2008, making the 2011 suit untimely.	Court held claim accrued when plaintiff learned of denial (Oct 2008); suit filed after two-year limit, so barred.
Qualified immunity for state officials	Beckstrand argues officials violated his rights in calculating parole credit.	Read and Simmons claim they acted pursuant to Hawaii statute and controlling state case law, entitling them to qualified immunity.	Court stated defendants would be entitled to qualified immunity for relying on statute and precedent, though it affirmed judgment on statute-of-limitations grounds.

Johnson v. California, 207 F.3d 650 (9th Cir.) (forum state statute of limitations governs § 1983 actions)
Knox v. Davis, 260 F.3d 1009 (9th Cir.) (accrual rule: claim accrues when plaintiff knows or has reason to know of injury)
TwoRivers v. Lewis, 174 F.3d 987 (9th Cir.) (same accrual principle)
Wallace v. Kato, 549 U.S. 384 (U.S.) (federal law governs when § 1983 claims accrue)
Cmty. House, Inc. v. City of Boise, Idaho, 623 F.3d 945 (9th Cir.) (officials acting in reliance on duly enacted statute entitled to qualified immunity)
Dittman v. California, 191 F.3d 1020 (9th Cir.) (same principle regarding reliance on statute)
State v. March, 11 P.3d 1094 (Haw. 2000) (holding sentencing court not authorized to grant credit for unrelated offense time)