Martin v. Julian, No. 20-3309 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit concluded that the district court did not err in determining plaintiffs' 42 U.S.C. 1983 claims for false imprisonment and unlawful search and seizure are time barred under Arkansas's three-year personal injury statute of limitations. In this case, the alleged Fourth Amendment violations -- false imprisonment and seizure of property based on fabricated evidence -- occurred before legal process began and are time-barred, despite plaintiffs' claim that the unlawful seizures continued even after the criminal charges were nolle prossed. The court rejected plaintiffs' contention that the district court improperly applied summary judgment standards in granting defendants' Federal Rule of Civil Procedure 12(b)(6) motions to dismiss and in denying plaintiffs' motion to vacate or set aside the dismissal. Rather, the court concluded that the district court did not abuse its discretion in declining to vacate or set aside its initial dismissal order because plaintiffs failed to state plausible section 1983 malicious prosecution claims under controlling Eighth Circuit precedent.
Court Description: [Loken, Author, with Colloton and Benton, Circuit Judges] Civil case - Civil rights. The district court did not err in determining plaintiffs' Section 1983 claims for false imprisonment and unlawful search and seizure are time barred under Arkansas's three-year personal injury statute of limitations; the district court did not abuse its discretion in declining to vacate or set aside its initial dismissal order because plaintiffs failed to state a plausible Section 1983 malicious prosecution claim under controlling Eighth Circuit precedent
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