Manuel v. City of Joliet
137 S. Ct. 911
SCOTUS2017Background
- Manuel was arrested March 18, 2011, after police stopped his car; officers alleged pills found were ecstasy although multiple tests showed no controlled substance.
- Police reports and an evidence technician allegedly contained fabricated statements that the pills tested positive.
- A county judge relied solely on the police complaint (containing the false statements) to find probable cause and ordered pretrial detention; Manuel remained jailed 48 days.
- After lab testing again showed no drugs, the prosecution dismissed the charge on May 4, 2011; Manuel was released May 5.
- Manuel sued under 42 U.S.C. § 1983 asserting Fourth Amendment claims for unlawful arrest and unlawful pretrial detention; lower courts dismissed his post-process detention claim based on Seventh Circuit precedent that such claims are Due Process claims, not Fourth Amendment claims.
- The Supreme Court granted certiorari to resolve whether the Fourth Amendment governs a claim challenging pretrial detention after the start of legal process when that detention is unsupported by probable cause.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Fourth Amendment continues to cover pretrial detention after legal process begins | Manuel: Fourth Amendment protection against unreasonable seizures extends beyond start of legal process; post-process detention founded on fabricated evidence lacks probable cause and is a Fourth Amendment violation | City: Once legal process begins (probable-cause finding, indictment), Fourth Amendment claims end and detainee must proceed under Due Process or be governed by accrual rules tied to process initiation | Held: Fourth Amendment governs challenges to pretrial detention even after the start of legal process when that detention lacks probable cause (reversing Seventh Circuit) |
| Whether legal process (e.g., judge’s probable-cause finding or indictment) extinguishes a Fourth Amendment claim | Manuel: No — if the process is tainted (fabricated evidence) it does not satisfy the Fourth Amendment probable-cause requirement | City: Legal process initiation fixes accrual and limits Fourth Amendment claims; claim should accrue at start of process | Held: Process that is tainted and does not establish probable cause does not eliminate a Fourth Amendment claim |
| Appropriate analog for accrual and favorable-termination requirement (malicious prosecution vs false arrest) | Manuel: Claim is analogous to malicious prosecution; accrual should wait until favorable termination (dismissal/release) so claim is timely | City: More like false arrest/false imprisonment; accrual should be at initiation of process; favorable-termination rule should not apply | Held: Court did not decide accrual/favorable-termination; remanded to lower courts to resolve accrual and timeliness issues |
| Whether court should adopt an accrual rule that treats each day of detention as a new Fourth Amendment violation (continuing violation) | Manuel: Accrual can be tied to dismissal/release; many circuits incorporate favorable-termination | City: Alternatively, plaintiff forfeited continuing-violation theory; accrual should be earlier | Held: Court declined to resolve continuing-violation or accrual; remanded for the Seventh Circuit to decide these questions (or consider waiver) |
Key Cases Cited
- Gerstein v. Pugh, 420 U.S. 103 (Fourth Amendment governs standards for pretrial detention and requires a judicial determination of probable cause)
- Albright v. Oliver, 510 U.S. 266 (claims alleging pretrial deprivations unsupported by probable cause belong under the Fourth Amendment)
- County of Riverside v. McLaughlin, 500 U.S. 44 (probable-cause determination must generally occur promptly after arrest; elaborates Fourth Amendment boundaries for pretrial detention)
- Wallace v. Kato, 549 U.S. 384 (accrual principles for § 1983 claims; false arrest/imprisonment accrues when detained pursuant to legal process)
- Heck v. Humphrey, 512 U.S. 477 (favorable-termination principle for malicious-prosecution analogies and limits on § 1983 recovery)
- Bailey v. United States, 568 U.S. 186 (probable cause is required for reasonable Fourth Amendment seizures)