Rickey Lee Christmas v. Grady Judd, 20-14431

In January 2015 Officer Manuel Palma conducted a protective sweep of Rickey Lee Christmas’s home and found methamphetamine.
The State brought drug-trafficking charges in October 2015 and Christmas was imprisoned pending trial in May 2016.
Since 2016 Christmas has filed fourteen federal § 1983 complaints; this suit was his twelfth, alleging an unreasonable search and false imprisonment.
The district court screened the pro se complaint under the Prison Litigation Reform Act (28 U.S.C. § 1915A) and dismissed it as barred by the statute of limitations.
On appeal Christmas did not contest the district court’s statute-of-limitations finding; he instead requested relief that the court construed as an equitable-tolling argument based on alleged denial of “discovery.”
The Eleventh Circuit reviewed the PLRA dismissal de novo, denied equitable tolling because no extraordinary obstacle or lack of diligence was shown (noting Christmas’s many other filings), and affirmed the dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the § 1983 complaint is time-barred	Christmas implicitly asks for tolling to avoid time-bar	Claims were filed after limitations period; dismissal appropriate	Affirmed dismissal as time-barred; plaintiff did not properly challenge the ruling
Whether equitable tolling applies	Tolling required because denial of “discovery” prevented timely filing	No extraordinary circumstance; Christmas filed many suits, so no delay excuse	Tolling denied — no extraordinary obstacle and no requisite diligence
Standard of review for PLRA dismissal	Pro se pleadings should be liberally construed	District court properly screened under § 1915A	Review is de novo; pro se allegations accepted but unraised arguments are abandoned
Whether appellate court may consider court records to assess timeliness	(implicit) relied on available record evidence	Judicial notice of district/state-court filings appropriate	Appellate court may take judicial notice of court documents to review the dismissal

Douglas v. Yates, 535 F.3d 1316 (11th Cir. 2008) (de novo review and liberal construction of pro se complaints under PLRA)
Timson v. Sampson, 518 F.3d 870 (11th Cir. 2008) (treating unraised arguments by pro se litigants as abandoned)
Villarreal v. R.J. Reynolds Tobacco Co., 839 F.3d 958 (11th Cir. 2016) (en banc) (standards for equitable tolling: diligence and extraordinary circumstance)
Lozman v. City of Riviera Beach, 713 F.3d 1066 (11th Cir. 2013) (appellate courts may take judicial notice of district- and state-court documents)
ITT Rayonier Inc. v. United States, 651 F.2d 343 (5th Cir. 1981) (same)