MEMORANDUM AND ORDER
Memorandum:
Supreme Court properly granted defendant's motion to dismiss the complaint, which alleges false arrest. A cause of action for false arrest accrues when the confinement terminates (see Kramer v. Herrera, 176 A.D.2d 1241; Boose v. City of Rochester, 71 A.D.2d 59, 64-65). The record establishes that plaintiff was arrested on August 21, 2000 for theft of services, based on his alleged refusal to pay for a room at defendant hotel that his family had occupied for several hours. Plaintiff was released from police custody on August 22, 2000 but did not commence this action until October 15, 2001. Thus, this action is time-barred (see CPLR 215; Boose, 71 A.D.2d 59), and we need not reach any other issues.