U.S. 5th Circuit holds statute of limitations was not jurisdictional, but trial judge should have reviewed matters raised at pretrial hearing under MSJ standards and dismissed the claims
Bradley v. Sheriff’s Department St. Landry Parish, 18-30600, (US 5th Cir – May 7, 2020)
This is a §1983/malicious prosecution case where the U.S. 5th Circuit dismissed a defendant’s claims against the law enforcement and related officials who prosecuted him.
Bradley was arrested and charged with conspiracy to commit armed robbery. He was arrested and housed in the St. Landry Parish Jail, then released that same day on bond. After being released, he was detained in another jurisdiction under an unrelated offense. While under this second incarceration, he was transported back to the St. Landry facility for one night so he could attend a hearing related to the conspiracy charge. He was later tried by a jury and acquitted four years later. Bradley sued the St. Landry Parish Sheriff’s Department and related officers alleging malicious prosecution, wrongful arrest and wrongful detention. The magistrate, sitting by consent, found he lacked jurisdiction to hear the civil suit and dismissed the claims based on the statute of limitations.
The U.S. 5th Circuit held the magistrate judge erred in concluding that, if Bradley’s § 1983 claims were barred by limitations, subject-matter jurisdiction over those claims was lacking. Section 1983 provides a federal cause of action but does not contain an express limitations period. The Supreme Court directs trial courts to look to state law personal injury claims for the limitations. The court held that statutes of limitations of this nature are procedural, not jurisdictional. However, while the magistrate may have had jurisdiction, the defendants raised the limitations defense in their pretrial order submission. As a result, prior to going to trial, it was required for the trial judge to evaluate the claims under a summary judgment standard (noting the magistrate gave the parties notice and an opportunity to respond to his inquiry on limitations). When a cause of action under § 1983 accrues is a question of federal law. For a false imprisonment claim, the accrual date begins when the imprisonment ceases. In Bradley’s case, the day as his arrest is the accrual date. Bradley’s wrongful arrest claim is barred by limitations, even if he contends that damages flowed from that false arrest until he was found not guilty. Bradley’s brief does not cite decisions regarding limitations for post-process pretrial detention claims. As a result, the wrongful detention claims also were filed outside the limitations’ period. Since Bradley points to no concealment of fact, no tolling of the limitations applies. Suits brought under § 1983 require the deprivation of a right guaranteed under the United States Constitution. The magistrate held that “[t]here is no constitutional right to be free from malicious prosecution,” and therefore Bradley “ha[d] no such federal claim.” The court recognized that a malicious prosecution claim could be viable if it is linked to a specific constitutional right. However, Bradley does not articulate any such right or any link. Simply asserting he has a constitutional right to be free of malicious prosecution under the 5th and 14th Amendments are all conclusory assertions devoid of any specifics. Such is insufficient to establish a claim. Further, Bradley inadequately briefed his “malicious prosecution” claim. In essence, the 5th Circuit held the trial court had jurisdiction but should have looked at the claims under a summary judgment standard, in which case, all federal claims would be dismissed.
If you would like to read this opinion, click here. The panel consists of Chief Justice Owen, Justices Clement and Ho.
