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Eaglin v. Eunice Police Department

Supreme Court of Louisiana

June 27, 2018

MARLON EAGLIN
v.
EUNICE POLICE DEPARTMENT, ET AL.

          ON WRIT OF CERTIORARI TO THE COURT OF APPEAL, THIRD CIRCUIT, PARISH OF ST. LANDRY

          PER CURIAM

         In this case, we are called upon to decide whether the false arrest and false imprisonment claims of Paul Powell are prescribed. For the reasons that follow, we conclude the action is prescribed. Accordingly, we reverse the judgment of the court of appeal and reinstate the judgment of the district court.

         FACTS AND PROCEDURAL HISTORY

         The relevant facts of this case are largely undisputed. On May 4, 2015, the Eunice Police Department arrested Marlon Eaglin, Paul Powell, and two others and charged them with second degree murder. Mr. Eaglin and Mr. Powell remained imprisoned until their release on August 21, 2015.

         On April 29, 2016, Mr. Eaglin filed the instant suit against the Eunice Police Department, the City of Eunice, and Chief Randy Fontenot (collectively referred to hereinafter as "defendants"), alleging false arrest and false imprisonment. On May 9, 2016, more than one year following the arrest, Mr. Eaglin amended his petition to add Mr. Powell as a party plaintiff.

         In response to the amended petition, defendants filed an exception of prescription, alleging Mr. Powell's claims for false arrest and false imprisonment were prescribed. Defendants argued Mr. Powell's claims prescribed on May 4, 2016, one year after the date of his May 4, 2015 arrest.

         Mr. Powell opposed the exception. He argued the amended petition adding his claim related back to Mr. Eaglin's timely-filed petition. In addition, Mr. 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 Mr. Powell's claims with prejudice. The district court initially rejected Mr. Powell's relation back argument, finding there was no legal or family relationship which would allow the amended petition adding Mr. Powell's claim to relate back to Mr. Eaglin's original claim. The court further reasoned that prescription on Mr. Powell's false imprisonment claim commenced to run on the date of his arrest, rather than his release from custody. Therefore, the court determined the claim was prescribed.

         Mr. Powell appealed, and the court of appeal reversed. Eaglin v. Eunice Police Department, 17-127 (La.App. 3rd Cir. 10/4/17), 228 So.3d 280. The court of appeal found that Mr. Powell's cause of action for false imprisonment began to accrue on the date of his release from prison. Because of this determination, the court of appeal pretermitted discussion of Mr. Powell's relation back arguments.

         Upon defendants' application, we granted certiorari to consider the correctness of this decision. Eaglin v. Eunice Police Department, 17-1875 (La. 3/9/18), ___ So.3d___ .

         Two issues are presented for our consideration: (1) whether prescription for false arrest and imprisonment commences on the date of the arrest or the date of release; and (2) if prescription runs from the date of arrest, whether an amended petition adding a new plaintiff relates back to an original petition filed within one year of the arrest. We will address these issues in turn.

         Prescription

         Defendants argue the suit is prescribed because it was clearly filed more than one year from Mr. Powell's arrest. However, Mr. Powell takes the position that prescription did not commence ...


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