Wallace v. Kato, 549 U.S. 384 (2007)

In the case of Wallace v. Kato, the underlying events began on January 17, 1994, when John Handy was shot and killed in Chicago. Two days later, Chicago police officers apprehended 15-year-old Andre Wallace and took him to a police station for questioning. Following extensive interrogations, Wallace confessed to the murder, signing a statement while waiving his Miranda rights. However, prior to his trial, Wallace attempted to suppress his confession, arguing it was obtained through an unlawful arrest. He was ultimately convicted of first-degree murder and sentenced to 26 years in prison. On appeal, the Illinois Appellate Court found that Wallace had been arrested without probable cause, violating his Fourth Amendment rights, and remanded the case for a new trial. The charges against him were dropped on April 10, 2002. Procedurally, Wallace filed a lawsuit under 42 U.S.C. §1983 on April 2, 2003, against the city of Chicago and several police officers, seeking damages for his unlawful arrest. The District Court granted summary judgment in favor of the defendants, and the Seventh Circuit Court of Appeals affirmed this decision, ruling that Wallace's §1983 claim was time-barred because it accrued at the time of his arrest rather than when his conviction was overturned. The Supreme Court granted certiorari to resolve the issue of the timeliness of Wallace's suit. The relevant background context includes the legal framework surrounding §1983 claims, which allows individuals to seek damages for violations of their constitutional rights. The statute of limitations for such claims in Illinois is two years, and the courts were tasked with determining when the statute began to run in Wallace's case. The Seventh Circuit ruled that it began at the time of his arrest, while a dissenting opinion suggested it should be based on the later invalidation of his conviction, referencing the precedent set in Heck v. Humphrey. This case thus highlights the complexities of timing in civil rights litigation following criminal proceedings.

Whether a cause of action under 42 U.S.C. §1983 for unlawful arrest accrues at the time of the arrest or at the time the underlying conviction is set aside.

The judgment is reversed and remanded.