Eaglin v. Eunice Police Dept.
Opinion Date: June 27, 2018
Judge: Per Curiam
Areas of Law: Civil Rights, Criminal Law
On May 4, 2015, the Eunice Police Department arrested Marlon Eaglin, Paul Powell, and two others and charged them with second degree murder. Eaglin and Powell remained imprisoned until their release on August 21, 2015. On April 29, 2016, Eaglin filed this lawsuit against the Eunice Police Department, the City of Eunice, and Chief Randy Fontenot (collectively, “defendants”), alleging false arrest and false imprisonment. More than one year following the arrest, Eaglin amended his petition to add Powell as a party plaintiff. In response to the amended petition, defendants filed an exception of prescription, alleging Powell’s claims for false arrest and false imprisonment were prescribed. Defendants argued Powell’s claims prescribed on May 4, 2016, one year after the date of his May 4, 2015 arrest. Powell opposed the exception, arguing the amended petition adding his claim related back to Eaglin’s timely-filed petition. In addition, Powell argued his claim for false imprisonment did not commence until the date he was released from prison (August 21, 2015), thereby making his May 9, 2016 claim timely. After a hearing, the district court granted defendants’ exception of prescription and dismissed Powell’s claims with prejudice. The district court initially rejected. Powell’s relation back argument, finding there was no legal or family relationship which would allow the amended petition adding Powell’s claim to relate back to Eaglin’s original claim. The court further reasoned that prescription on Powell’s false imprisonment claim commenced to run on the date of his arrest, rather than his release from custody. After its review, the Louisiana Supreme Court concluded the action was prescribed. Accordingly, the Court reversed the judgment of the court of appeal and reinstated the judgment of the district court.
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