Johnny Bernard Smith III v. Officer Reid T. Nakamura, et al.

Summary

The United States District Court for the District of Hawai‘i granted the City and County of Honolulu’s motion to dismiss Johnny Bernard Smith III’s First Amended Complaint alleging unlawful seizure, excessive force, and municipal liability under 42 U.S.C. § 1983. The court held that the claims were barred by Hawai‘i’s two-year statute of limitations and rejected equitable tolling and equitable estoppel arguments. The court dismissed the amended complaint in its entirety, including the claims against Officer Nakamura, without leave to amend.

Holdings

1. Smith's Section 1983 claims were governed by Hawai‘i's two-year statute of limitations and accrued no later than May 29, 2023, when the alleged handcuffing and resulting injury occurred. Because the original complaint was filed on July 1, 2025, the claims were untimely.
2. Smith did not establish a basis for equitable tolling or equitable estoppel. His later medical evaluations and the delayed administrative disposition did not excuse his late filing.
3. The First Amended Complaint was dismissed without leave to amend because Smith had already been given an opportunity to cure the timeliness defects and had not alleged grounds for tolling; further amendment would be futile.

Questions Presented

1. Whether Smith's Section 1983 claims were barred by Hawai‘i's two-year statute of limitations.
2. Whether later discovery of the full extent or permanence of Smith's injuries delayed accrual of his Section 1983 claims.
3. Whether the Honolulu Police Commission's delayed administrative decision supported equitable tolling or equitable estoppel.
4. Whether the First Amended Complaint should be dismissed without further leave to amend after Smith had already been given an opportunity to amend.

Disposition

dismissed