Legal Opinion

James Randall v. Philadelphia Law Department

Court of Appeals for the Third Circuit

Decided March 20, 2019No. 18-2303PublishedCited by 52 opinions

1Opinion of the Court

BIBAS, Circuit Judge.

When a defendant commits a continuing violation of the law, the limitations period starts running from the defendant's last act, not from when the effects of that violation end. Here, the defendants arrested and prosecuted James Randall in Philadelphia for drug and weapons crimes. As a result of that prosecution, New Jersey and Delaware County, Pennsylvania, lodged detainers against Randall for violating his probation. So he remained in those jurisdictions' custody until December 2015. But the defendants' last act was in August 2015, when they dropped the charges and sent…

2Cases cited4 opinions

  1. Heck v. HumphreySupreme Court of the United States · 1994
  2. Wallace v. KatoSupreme Court of the United States · 2007
  3. Eileen Cowell v. Palmer TownshipCourt of Appeals for the Third Circuit · 2001
  4. Kelly Conard v. Pennsylvania State PoliceCourt of Appeals for the Third Circuit · 2018

3Cited by52 opinions

  1. Heraeus Medical GMBH v. Esschem IncCourt of Appeals for the Third Circuit · 2019
  2. ABDULLAH v. ROWAN UNIVERSITYDistrict Court, D. New Jersey · 2024
  3. ALEXIS v. SESSIONSDistrict Court, D. New Jersey · 2023
  4. AUSTIN v. DISTRICT ATTORNEY'S OFFICE OF NORTHAMPTON COUNTYDistrict Court, E.D. Pennsylvania · 2022
  5. Ali v. Commissioner Robert CoupeDistrict Court, D. Delaware · 2019

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