Wallace v. City of Chicago
Issues
When does the statute of limitations for a damages claim arising out of a false arrest or other search and seizure prohibited by the Fourth Amendment begin to run when evidence collected during the illegal arrest or search is used to convict the claimant during a criminal trial and the conviction is later overturned?
Andre Wallace was tried for and convicted of murder based on a confession obtained by Chicago detectives when he was fifteen years old. After several appeals, Wallace’s conviction was annulled by the Illinois Appellate Court, which held that Wallace was arrested without probable cause and that his unlawfully obtained confession could not be used to convict him of murder because it was not “sufficiently attenuated from his unlawful arrest.” Wallace v. City of Chicago, 440 F.3d 421, 422 (7th Cir. 2006). Left with no other substantial evidence to convict Wallace, the prosecution dropped all charges against him. Wallace then sued the City of Chicago as well as Detectives Kristen Kato and Eugene Roy, under 42 U.S.C. § 1983, for violating his Fourth Amendment rights. The district court granted the detectives and the City of Chicago summary judgment on all of Wallace’s claims for his failure to meet the two-year statute of limitation. The Seventh Circuit affirmed the district court’s decision and found that “false arrest claims accrue at the time of the arrest,” rather than at the time the claimant’s conviction is overturned, concluding that Wallace’s claim was barred. Wallace v. City of Chicago, 440 F.3d at 423. The Seventh Circuit majority and dissent indicate the existence of a conflict between circuit courts as to when the statute of limitations begins to run for damages claims resulting from false arrests. The Supreme Court granted certiorari to resolve the conflict. The Supreme Court’s decision in this case will reflect its view on the correct balance between state interests, such as efficiency in the trial process, and the rights of individual defendants, such as having the opportunity to recover for damages arising from ? 1983 violations. Whether the statute of limitations begins to run at the time of arrest or at the time a conviction is overturned will influence when a claimant will be able to bring ? 1983 claims and may limit the availability of remedies for ? 1983 claims.
Questions as Framed for the Court by the Parties
When does a claim for damages arising out of a false arrest or other search or seizure forbidden by the Fourth Amendment accrue when the fruits of the search were introduced in the claimant’s criminal trial and he was convicted?
On January 17, 1994, John Handy was shot and killed in a building located at 825 North Lawndale Avenue in Chicago. Wallace v. City of Chicago, 440 F.3d 421, 423 (7th Cir. 2006).