Elijah Manuel v. City of Joliet, 903 F.3d 667

Elijah Manuel was arrested on March 18, 2011 for possession of pills; a judge ordered him held pending trial that day.
Prosecutor dismissed the charge on May 4, 2011 after concluding the pills were legal; Manuel was released May 5, 2011.
Manuel sued under 42 U.S.C. § 1983 on April 22, 2013 alleging detention without probable cause in violation of the Fourth Amendment.
Illinois law supplies a two-year statute of limitations for the § 1983 claim; federal law governs when the claim accrued.
Defendants argued accrual occurred March 18 (when judge ordered custody); Manuel argued accrual occurred May 4 (dismissal/vindication).
The Seventh Circuit held the claim accrued on May 5 (the date of release), making the suit timely and reversed the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does a Fourth Amendment claim for detention without probable cause accrue?	Accrues on dismissal/vindication of charges (May 4).	Accrues when judicial process began/when bound over (March 18), per Wallace.	Accrues when detention ends (date of release, May 5).
Does Wallace v. Kato govern accrual for wrongful pretrial detention?	Manuel argued Wallace’s rule does not control detention challenges that continue after process begins.	Defendants relied on Wallace that accrual occurs upon initiation of legal process.	Wallace’s single-line rule does not apply to ongoing detention claims after Manuel; accrual waits until the wrongful custody ends.
Is analogy to malicious prosecution appropriate for accrual?	Manuel urged a malicious-prosecution analogue where claim accrues on vindication.	Defendants previously conceded that if the claim were "Fourth Amendment malicious prosecution" accrual would be on vindication.	Supreme Court in Manuel rejects malicious-prosecution framing; the claim is a straight Fourth Amendment detention claim, so accrual follows detention dates.
Does Preiser/Heck bar a §1983 suit while judicially-authorized custody continues?	Manuel argued he could not sue while detained.	Defendants argued accrual on judicial binding date despite detention.	Preiser/Heck/Edwards require waiting until release (or availability to sue) when custody is judicially authorized; claim cannot accrue while detention continues.

Manuel v. Joliet, 137 S. Ct. 911 (2017) (held detention without probable cause is actionable under the Fourth Amendment and rejected the malicious-prosecution analogy)
Wallace v. Kato, 549 U.S. 384 (2007) (held Fourth Amendment claims generally accrue when legal process begins; court relied on but limited its scope)
Wilson v. Garcia, 471 U.S. 261 (1985) (state statute of limitations governs §1983 claims)
National Railroad Passenger Corp. v. Morgan, 536 U.S. 101 (2002) (continuing violations doctrine: statute runs when wrong ends for ongoing violations)
United States v. Kubrick, 444 U.S. 111 (1979) (accrual principles for federal claims)
Delaware State College v. Ricks, 449 U.S. 250 (1980) (accrual and continuing wrong distinction)
Preiser v. Rodriguez, 411 U.S. 475 (1973) (habeas is the proper vehicle to challenge ongoing state custody)
Heck v. Humphrey, 512 U.S. 477 (1994) (limits on §1983 claims that would imply the invalidity of a conviction; claim not cognizable until conviction set aside)
Edwards v. Balisok, 520 U.S. 641 (1997) (Heck principle extended to certain administrative custody deprivations)
Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (Fourth Amendment claims analyzed under objective probable-cause standards)