Supreme Court of the United States · Official docket →
John Alan Sakon v. John Johnson, Officer of the Glastonbury Police Department, et al.
IFP petition · United States Court of Appeals for the Second Circuit, No. 24-1991 · judgment February 17, 2026
Questions presented
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Whether the rule that a Fourth Amendment malicious-prosecution claim under 42 U.S.C. § 1983 accrues on the date a nolle prosequi is entered, as the 2nd Circuit Court's decision in Spak v. Phillips, 857 F.3d 458 (2d Cir. 2017), was applied by the panel below, survives Thompson v. Clark, 596 U.S. 36 (2022), which held that such a claim accrues only when the underlying criminal proceeding has been disposed of in a manner that “cannot be revived.” I
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Whether, under Erie Railroad Co. v. Tompkins, 304 U.S. 64 (1938), a federal court may apply a claim-accrual rule for the state-law tort underlying a § 1983 malicious-prosecution claim that conflicts with the accrual rule the State itself has enacted, Conn. Gen. Stat. § 52-577f, and confirmed through its appellate courts, Lopes v. Farmer, 286 Conn. 384 (2008), and Washington v. Ivancic, 113 Conn. App. 131 (2009).
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Whether the court of appeals committed reversible error by affirming dismissal of Petitioner's claims as time-barred without addressing the tolling provision of 11 U.S.C. § 108(a), where Petitioner's claims were property of a bankruptcy estate, subject to an automatic stay, and were not abandoned back to him until the bankruptcy court's order of August 1, 2021 — a dispositive, squarely presented question of federal statutory law that the panel's summary order does not address. Page 2 of 32 r a
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Whether an officer's arrest warrant application can establish probable cause for larceny as a matter of law where the application accounts only for the income a property manager received from the property, with no accounting for the correlative business expenses the officer knew the manager was responsible for I paying, and where an accounting of those expenses was independently available in the municipal Assessment records but the officer failed to review it. Page 3 of 32
Counsel of record
For petitioner
John Alan Sakon
For respondent
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Case
Subject area
Civil Rights (estimated from the questions presented, in the Supreme Court Database’s categories)
Conference history
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Linked docket
25A1411
Proceedings
- Aug 20 2026Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due November 16, 2026)
- Jun 18 2026Application (25A1411) granted by Justice Sotomayor extending the time to file until August 21, 2026.
- Jun 08 2026Application (25A1411) to extend the time to file a petition for a writ of certiorari from June 22, 2026 to August 21, 2026, submitted to Justice Sotomayor.