The following excerpt is from Warren v. Sawyer, 16-1617-cv (2nd Cir. 2017):
Warren first attempts to avoid this conclusion by arguing that the prison mailbox rule should be extended to individuals confined to medical facilities. Even were that rule applicable and his complaint deemed filed on May 9, 2015, however, his claims still would be untimely becausealthough May 10, 2012, was the latest date on which his claims could possibly have accruedall of the factual allegations in his complaint show that he was aware of the alleged harms giving rise to his claims well before that date. See, e.g., Covington v. City of New York, 171 F.3d 117, 121 (2d Cir. 1999) (explaining a Section 1983 claim accrues "when the plaintiff knows or has reason to know of the injury which is the basis of his action").
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