Alex Luciano Beyhawck v. Washington State Patrol et al.

Summary

The United States District Court for the Western District of Washington granted the Washington State Patrol and Officer Andy Stoeckle’s motion to dismiss Alex Luciano Beyhawck’s claims arising from a 2020 traffic stop, search, seizure, and prosecution. The court held that the state-law claims were prematurely filed because the required tort-claim waiting period had not elapsed, and that the federal and state claims were barred by the applicable statutes of limitations. The court dismissed the action without leave to amend and directed the Clerk to close the case.

Holdings

1. Washington Revised Code §§ 4.92.100 and 4.92.110 impose mandatory claim-filing and 60-day waiting requirements that operate as conditions precedent to state tort claims against Washington and its officers or employees acting in their official capacities. Filing the tort claim only thirteen days before commencing suit did not satisfy the statutory waiting period.
2. Plaintiff's § 1983, negligence, and conversion claims were barred by Washington's three-year statute of limitations because they accrued from the October 6, 2020 traffic stop and Plaintiff did not file suit until October 7, 2025.
3. Plaintiff's malicious prosecution claim was time-barred because it accrued when the underlying proceedings terminated on August 8, 2022, and Plaintiff filed suit more than three years later.
4. Plaintiff did not establish equitable tolling, and Washington Revised Code § 4.92.110 did not toll his claims because he presented his tort claim only after the limitations periods had expired.
5. Plaintiff could not pursue a damages action directly under Article I, section 7 of the Washington Constitution because Washington law does not recognize such a private cause of action absent legislative guidance.

Questions Presented

1. Whether Plaintiff's Washington tort claims were barred by failure to satisfy Washington's statutory tort-claim presentment and 60-day waiting requirements.
2. Whether Plaintiff's § 1983, negligence, and conversion claims were barred by the applicable three-year statutes of limitations.
3. Whether Plaintiff's malicious prosecution claim was barred because it was filed more than three years after termination of the underlying proceedings.
4. Whether equitable tolling or Washington's statutory tolling provision saved Plaintiff's claims.
5. Whether Plaintiff could maintain a damages action directly under Article I, section 7 of the Washington Constitution.

Disposition

dismissed