Chiaverini v. City of Napoleon, 602 U.S. 556

Jascha Chiaverini, a jewelry store owner in Napoleon, Ohio, was charged by local police officers with three offenses: receiving stolen property (misdemeanor), dealing in precious metals without a license (misdemeanor), and money laundering (felony).
Based on police affidavits focused on the felony, a warrant issued, leading to Chiaverini’s arrest and three-day detention; prosecutors later dropped all charges after not presenting the case to a grand jury on time.
Chiaverini sued the officers under 42 U.S.C. §1983, claiming violations of his Fourth Amendment rights through malicious prosecution, arguing specifically there was no probable cause for the felony charge.
The District Court and Sixth Circuit both sided with the officers, holding that probable cause for any charge (here, the misdemeanors) barred a malicious prosecution claim even if other charges (the felony) lacked probable cause.
A circuit split existed, as other appellate courts allowed malicious prosecution claims in similar scenarios; the Supreme Court granted certiorari to resolve this split.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does probable cause for any charge defeat a malicious prosecution claim for other baseless charges?	Probable cause for one charge does not bar Fourth Amendment claims relating to invalid charges.	Probable cause for any charge bars such Fourth Amendment claims.	No, probable cause for one charge does not categorically defeat claims about other baseless charges.
What is the appropriate causation standard when some charges are valid and others are not?	Any detention resulting from a warrant tainted by baseless charges satisfies causation.	Only if judge could not have lawfully authorized detention absent the bad charge.	Issue not decided; remanded to Sixth Circuit to resolve.
Should the approach be charge-by-charge or categorical for Fourth Amendment claims?	Claims must be considered per charge; one baseless charge is enough for a claim.	Only all charges lacking probable cause justifies a claim; one valid charge insulates from liability.	The analysis must be charge-by-charge, not categorical.
Is a Fourth Amendment malicious prosecution claim a proper constitutional analogue?	Yes; wrongful charges lacking probable cause causing seizure fit the Fourth Amendment.	No; malicious prosecution is a tort better rooted in due process (Fourteenth Amendment).	Majority reaffirms Fourth Amendment claim is appropriate; dissent disagrees.

United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (explains that a court syllabus is not part of the decision itself)
Manuel v. Joliet, 580 U.S. 357 (Fourth Amendment pretrial detention must be based on probable cause)
Thompson v. Clark, 596 U.S. 36 (malicious prosecution claim can proceed under the Fourth Amendment)
Rodriguez v. United States, 575 U.S. 348 (even justified detentions can become unconstitutional if prolonged by a lack of cause)