May 08th, 2020

Bradley v. Sheriff's Department St. Landry Parish

Docket: 18-30600
Opinion Date: May 7, 2020
Judge: Priscilla Richman Owen
Areas of Law: Civil Rights, Constitutional Law

Plaintiff filed suit against the Sheriff's Department and others under 42 U.S.C. 1983 and Louisiana state law, alleging wrongful arrest, wrongful detention, and malicious prosecution. The Fifth Circuit vacated in part the district court's dismissal based on lack of subject matter jurisdiction, rendering judgment in favor of each defendant on each of the federal law claims. The court held that the magistrate judge erred in concluding that, if plaintiff's section 1983 claims were barred by limitations, subject matter jurisdiction over those claims was lacking. The court held that the section 1983 claims based on wrongful or false arrest and wrongful detention were time-barred, and the court declined to apply equitable tolling to the claims. The court also held that defendant inadequately briefed his malicious prosecution claim, and dismissal of the pendant state-law claims was within the district court's discretion. Accordingly, the court affirmed the judgment to the extent it dismissed plaintiff's state law claims.

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