Trenton Robinson v. Erik Norling, 25 F.4th 1061

Robinson was arrested and allegedly beaten by police; he filed a 42 U.S.C. § 1983 suit six years and one day after the arrest.
The day before he filed was Veterans Day, a federal holiday; federal courthouses were closed, so he filed on the next business day.
Defendants moved to dismiss three of four § 1983 claims as time-barred under Minnesota’s six-year statute of limitations.
At oral argument the district court raised the federal-holiday rule (extending filing deadlines that fall on federal holidays), but Robinson did not press that argument; the court dismissed the privacy, excessive-force, and false-arrest claims as untimely and dismissed malicious-prosecution on the merits.
Robinson sought to raise the federal-holiday rule later; the district court refused. On appeal the parties agreed the federal-holiday rule would make those claims timely.
The Eighth Circuit held the holiday-tolling argument was forfeited but excused the forfeiture under narrow exceptions and remanded the three claims; it affirmed dismissal of the malicious-prosecution claim as not a constitutional violation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether filing on the next business day after a federal holiday satisfies the limitations deadline	Robinson: federal-holiday rule extends the deadline so claims are timely	Defendants: claims filed after six-year limit and thus untimely	Court: holiday rule applies; those claims are timely and must be reinstated on remand
Whether Robinson forfeited or waived the holiday-tolling argument by not raising it below	Robinson: failure was an inadvertent oversight; he sought relief later	Defendants: district-court promptness required; argument abandoned	Court: failure was forfeiture (not waiver) but excused because resolution is a purely legal issue beyond doubt
Whether the court can consider a forfeited argument on appeal	Robinson: appellate review should correct obvious legal error	Defendants: appellate courts should not resurrect forfeited arguments	Court: exercised discretion to consider and correct the error under established exceptions
Whether malicious-prosecution states a § 1983 claim	Robinson: alleged malicious prosecution arising from arrest and prosecution	Defendants: malicious prosecution alone is not a constitutional claim	Court: affirmed dismissal—malicious prosecution alone does not state a § 1983 claim

Rassier v. Sanner, 996 F.3d 832 (8th Cir. 2021) (statute-of-limitations rules for § 1983 actions)
Olano v. United States, 507 U.S. 725 (1993) (distinguishes waiver and forfeiture principles)
McCorkle v. United States, 688 F.3d 518 (8th Cir. 2012) (defining waiver vs. forfeiture in appellate review)
Weitz Co. v. Lloyd’s of London, 574 F.3d 885 (8th Cir. 2009) (excusing forfeiture when resolution is beyond doubt or purely legal)
Newton v. Clinical Reference Lab., Inc., 517 F.3d 554 (8th Cir. 2008) (limits on appellate discretion to consider forfeited issues)
Kohl v. Casson, 5 F.3d 1141 (8th Cir. 1993) (malicious prosecution alone is not a constitutional § 1983 claim)
Kurtz v. City of Shrewsbury, 245 F.3d 753 (8th Cir. 2001) (same principle on malicious prosecution and § 1983)
Wallace v. Kato, 549 U.S. 384 (2007) (limitations period for false-arrest claim may begin at end of detention)