Jeffrey Swiecicki v. Jose Delgado

I agree with the court’s disposition of Swiecicki’s false-arrest claim and ■ write *504separately to express some reservations about the disposition of the other two counts — the excessive-force and free-speech claims.

At first blush, it would seem to me, the district court correctly rejected Swiecicki’s excessive-force claim as a matter of law because it was time barred. The statute of limitations for an excessive-force claim generally runs from the date of the abusive police conduct. That is not the case, however, if success on the § 1983 claim would “necessarily imply the invalidity of his…