ad he was held all the way intel four months later on january fourteenth the twenty fourteen when the bonds finally released mr brown filed suit within two years when the bond was released we have a narrow little question on appeal here which is whether the claim accrues when someone is released from being physically in the jail versus when they're released from the bot the facts in this case are that first mr brown is sentenced in july of two thousand and thirteen when he says he sets a seventy nine days the however we'll get to bet so the issue is so if he first knew about his problem then that where's the proper remedy where does he go to get that remedy he goes to state court his only option is in state court the law's clear and this court has found two months ago or two weeks ago that you what happened with the first news eventually got heard on december sixteenth ok it wasn't her because the cook county jail failed to transport him to court on three separate occasions when it finally gets heard on december sixteenth there isn't actually a rul instead the judge sees mr brown in court and what are you doing here i thought you're supposed to be out on september twelfth the state's attorney argues mr brown should still be incarcerated he should still be in prison and jail scuse me and tell mark and they argue that he bond on that date he doesn't rule he doesn't say that anything was incorrect he simply is through trying to maintain the status quo the best he can by releasing mr brown on bought with conditions on bond so releases possess a firearm you can't leave the state now there's ample case law that the state can be a person and there's a law that you know possessing a firearm is a fundamental right to right that he should have those rights or deprive them return to court now meanwhile when he returned back on january fourteenth there was no assurance that he would be returned back to jail the issues are still outstanding as to whether the sentence was assessed correctly as to whether he had served bad time it was up in the air there was no finality of the proceeding until january twenty fourth teen prior to january of two thousand and fourteen he had no plan because the state court proceeding was still gump had he gone into federal court they'd say go back to state is is being held on and i bought fifty thousand dollars bond being detained pursuant to legal process and i think it's absolutely yes there's no way to say being held on a fifty thousand dollar i bond being confined to the state not be able to firearm after to return to court is not being help or start a legal process so mr brown finally files pro se complaint on december thirtieth of two thousand and sixteen which is within two years of when he was finally released from legal case is wilson's right on point to dry i added to the record yesterday morning for the state court proceedings to be done for the claim to prove the state court proceeding was still going as of january twenty fourth team and that the key thing here is that between december thirtieth and january seventeenth the criminal court could have sent him back to jail there is no final ruling as to  as to whether the the term of the sentence was and it was proper there is no determination is in his favor up until that point instead there was simply i think that we might have screwed up so why don't you go home for a month that is not a final ruling and most importantly the state's attorney was still pushing for him to stay in longer and they're still arguing that and then all this time lays out on bond his rights are extremely restrained you can't leave the state which is  or any policy that would allow this court to breach him from december sixteenth of two thousand and thirteen to january seventeenth of two thousand and fourteen he has not and therefore this court should no the facts are that on december sixteenth of two thousand and thirteen the interactions between the plaintiff and the defendant in this case the sheriff were conclud provides not a single fact that has any interaction with the sheriff the defendant in this case post december sixteenth two thousand and thirteen instead it was said that most that's the last day that is the last day your honor and in fact as my colleague conceded it on december sixteenth the twenty thirteen it was the state criminal trial court not the sheriff who put mr brown on i bond it was the court not the sheriff that triggered the i bond conditions it was statute seven twenty five i a last five to one ten paragraph three prohibits you from leaving the state without permission from the court in paragraph five require you to turn over any firearms beginning i would call that a new beginning right at that that's correct the any claim against the sheriff concluded as of december sixteen of twenty thirteen his claims against the sheriff accrued at that point complaint it's a five count complaint count three is a state claim for false imprisonment that's a one year statute of limitations plaintive conceded that that claims time for count four in five are for conditions in the jail while he's clearly out of the jail on december sixteenth of two thousand and thirteen so those claims accrued at that point and he had two years to file he did  not and so those counts should be out so really the only counts for this court to really focus on are council wanted to the over incarceration or false imprisonment claims and as  my colleague correctly stated the wallace case does indeed address this issue square in wallace the court said that the false imprisonment  defined as being held without lawful process and that false imprisonment ends wants you are held pursuant to a lawful process as my colleague correctly stated therefore as of december sixteenth of twenty thirteen when the state criminal trial court judge put mr brown on  was then that being held pursuant to a lawful process and the false imprisonment claims counts one into a crude at that point against the ship n or invalidate either the conviction or the sentence the heck would a plot here as my colleague correctly stated the state court judge said on the equitable tolling applies where there is an extraordinary bar to a plaintiff filing suit and mr brown has presented no such extraordinary bar to filing suit immediately after december sixteenth of two thousand and thirteen or two years or within two years from that date third he relies on continuing violation and as this court stated in evidence  which is cited on page twelve of our brief this court in continuing violations looks to the contacts between the plaintiff and the defendant in evans the court cut off any violation no further contact with the ship and so there can be no continuing violation after that date lastly and most recently my colleague relies on the wilson case the wilson case extension and this court even recognized that had he not filed in state court that he could have moved forward with his section nine hundred eighty three action here none of that is applicable to the share the plate to mr brown and the sheriff had all of their business concluded with each other as of december sixteenth of two thousand and thirteen and mr brown could have sued at that point or any time within the next two years instead he waited until december thirtieth of two thousand and fifteen and his claims are time barred lastly terms of policy in order to reverse that this report this court would have to do three things first it would have to find that the i bond is somehow confinement or custody it is not the albright case decided that that issue twenty five years ago and the plaintiff has provided no reason to overturn that longstanding precedent even if you were inclined to do that you would then have to find that the i bonds was somehow false can fin found that somehow it was fault then you would have to say that all of that was the sheriff's fault and as we've discussed it is not because the sheriff and mr brown concluded their business as of december sixteenth tw extreme if somebody is false and falsely imprisoned by an officer allen oil and then transferred to supermax in colorado and spends ten years there and then is released his cause of action accrues ten years later he's released ten years for any talent act with anyone in illinois so here the time of when the cook county sheriff had any interaction with mr brown is being this it's completely irrelevant about custody be the custody issue is key he was released from custody on january fourteenth when did or didn't do in relation to the timing of his release the question is when is he released he's released from the i bond in january to what you're saying is i think you said when he was released from the i bond that   there's no ruling from any court that you supposed to be out prior to january twenty fourth twenty fourteen so every man is it's one little narrow issue as whether being held on bond counts is going fight that's that's the tiny little question that we have but here and the there is very little risk of slippery slope here there's very little risk of this coming up again it's such a weird unique issue where a judge doesn't quite rule where he sent someone home to a tool later i don't perceive as coming up again for mr brown this is imperative and this man has been you know where housed in the cook county dungeon and denied all his constitutional rights to try to get out and he finally you know seeks remedy and he's allegedly thirteen days late it's it's not just big picture and we have a completely broken system the county it's a disaster and this man is is suffering