New York's statute of limitation for false arrest starts to run when you are seized or taken into custody. A one-year limitations period also governs a New York state law claim for assault, battery, and false imprisonment. See CPLR § 215. The courts have held that claims for false arrest or excessive force accrue on the date the arrest is made or the force is used. See Ormiston v Nelson, 117 F3d 69, 71 (2d Cir 1997). According to the United States Supreme Court, the forum state's personal injury statute of limitations governs. See Wilson v Garcia, 471 US 261 (1985); Owens v Okure, 488 US 235 (1989).