U.S. Second Circuit - The FindLaw 2nd Circuit Court of Appeals Opinion Summaries Blog

Citizen Loses Award on Appeal for 3 Years of Unlawful Imprisonment

The case of Davino Watson vs. the U.S.A. is one that most citizens would probably have preferred losing. The case is one of true bureaucratic incompetence, insurmountable legal hurdles, and precedential tragedy.

Mr. Watson, while incarcerated on a drug charge, was investigated by ICE. The ICE case was mishandled so badly that Mr. Watson, a U.S. citizen, was held for three years after he finished serving his time on the drug charge. After his eventual release, he filed suit to recover for the time he was falsely imprisoned by the federal government due to bureaucratic incompetence. He won at the trial level, but had his damages limited. However, on appeal, the court reluctantly stripped Mr. Watson of that win.

What?!

Basically, the appellate court found that Mr. Watson failed to meet the statute of limitations for filing his claim. While the trial court agreed with the plaintiff's arguments on equitable tolling, the appellate court was not convinced and followed SCOTUS precedent. The appellate court found that Mr. Watson should have filed his claim within two years from first being taken into custody for deportation.

Essentially, the court of appeals took away the one and only claim that Mr. Watson had succeeded on. The tone of the decision is clearly apologetic, but decisive, as it quickly explains that U.S. Supreme Court precedent held similarly in another sympathetic case with similar facts.

Wait ... WHAT?!

The apologetic tone may not be comforting to many. In fact, the opinion itself calls the decision into question. In some brief dicta, the opinion offers a dissenting viewpoint and explains that "this is the first time this Circuit has ever reversed a district court's decision to grant equitable tolling in such a fashion." This seems rather significant of an admission. However, the court's analysis presented relatively weak bases for the tolling.

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