context: The Supreme Court found that the false imprisonment ends for either tort when the victim is released, or when the victim's imprisonment becomes "pursuant to [legal] process -- when, for example, he is bound over by a magistrate or arraigned on charges." Id. Moreover, several states have found that claims for false arrest and false imprisonment accrue when the false imprisonment ends or when imprisonment becomes pursuant to legal process.
citation_a.signal: see
citation_a.identifier: 41 F.Supp.2d 216, 216
citation_a.parenthetical: "Under New York law, false arrest and false imprisonment claims accrue on the date of the release from confinement."
citation_a.sentence: See Hoffman v. County of Delaware, 41 F.Supp.2d at 216 (“Under New York law, false arrest and false imprisonment claims accrue on the date of the release from confinement.”), aff'd 205 F.3d 1323 (2d Cir.2000); Adler v. Beverly Hills Hosp., 594 S.W.2d at 154 (“We hold that false imprisonment is a continuing tort and that the cause of action for the entire period of imprisonment accrues when the detention ends.”); Belflower v. Blackshere, 281 P.2d at 425 (holding that a cause of action for illegal arrest and false imprisonment accrued at the time plaintiff was released from his alleged illegal restraint and not when the proceedings by which his arrest occurred terminated).
citation_b.signal: see also
citation_b.identifier: 226 S.W.3d 68, 72
citation_b.parenthetical: holding that the false imprisonment ended when the plaintiff began being held pursuant to legal process -- the date when he was arraigned on the charges
citation_b.sentence: See also Johnson v. Blackwell, 885 N.E.2d 25, 31 (Ind.Ct.App.2008)(holding that “Johnson’s cause of action for false imprisonment/false arrest accrued when he was bound over for trial in March 2003”); Dunn v. Felty, 226 S.W.3d 68, 72 (Ky.2007)(holding that the false imprisonment ended when the plaintiff began being held pursuant to legal process — the date when he was arraigned on the charges).