Bryant v. City of Chicago

Dist. Ct. erred in dismissing plaintiff-prisoner’s untimely section 1983 complaint alleging false arrest and false imprisonment by two unnamed defendants-police officers, who stopped plaintiff on his bicycle without warrant and arrested him for possession of controlled substance, where seizure of drugs was eventually suppressed, and where charges against plaintiff were dismissed. While Dist. Ct. based dismissal on plaintiff’s failure to identify police officers prior to expiration of limitations period, Dist. Ct. should have equitably tolled any limitations period to allow plaintiff time to learn of identity of said defendants where: (1) Dist. Ct. had not addressed plaintiff’s pending motion to compel defendant to produce names of said officers; (2) plaintiff’s incarceration on unrelated charges made it difficult for him to learn of officers’ identity; and (3) plaintiff otherwise acted with reasonable diligence in obtaining missing information.