Maurice Lewis v. City of Chicago
914 F.3d 472
| 7th Cir. | 2019Background
- Maurice Lewis was arrested after police found a handgun in an apartment; officers allegedly fabricated reports saying Lewis admitted residence at the apartment and that evidence showed he lived there.
- A state judge found probable cause at a post-arrest hearing and Lewis remained in Cook County Jail for about two years until charges were dropped on September 29, 2015.
- Lewis sued the City of Chicago and six officers under 42 U.S.C. § 1983 (Fourth Amendment and Fourteenth Amendment due process) and raised an Illinois malicious-prosecution claim; suit filed July 26, 2016.
- The district court dismissed the constitutional claims with prejudice as time-barred under Illinois’s two-year limitations period and declined supplemental jurisdiction over the state claim.
- On appeal the Seventh Circuit applied Supreme Court and Seventh Circuit precedent (Manuel decisions) to determine whether a wrongful-pretrial-detention claim sounds under the Fourth Amendment and when such claims accrue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether pretrial detention based on fabricated evidence states a Fourth Amendment claim | Lewis: detention based on falsified reports violates Fourth Amendment (unreasonable seizure) | Defendants: once legal process begins, Fourth Amendment claim is displaced by due-process/malicious-prosecution theory | Held: Fourth Amendment governs wrongful pretrial detention; Lewis pleaded a plausible Fourth Amendment claim (Manuel I/II controlling) |
| When a Fourth Amendment claim for wrongful pretrial detention accrues | Lewis: accrual occurs when detention ends; suit filed within two years of release | Defendants: claim accrued earlier, making suit time-barred | Held: accrual occurs when detention ceases; Lewis’s § 1983 claim was timely |
| Whether the same facts support an independent Due Process Clause claim for pretrial detention | Lewis: fabricated evidence also violates Fourteenth Amendment due process, so a separate claim lies | Defendants: detention claims should be evaluated under Fourth Amendment; due-process claim barred or duplicative | Held: Due Process does not provide a separate basis for wrongful pretrial detention under § 1983; Hurt v. Wise to the extent it held otherwise is overruled |
| Qualified immunity for the officers | Defendants: officers are entitled to qualified immunity because law was not clearly established | Lewis: Franks and precedent clearly established that fabricating evidence leading to probable-cause findings violates the Constitution | Held: reasonable officers would know falsifying evidence to secure probable cause is unconstitutional; qualified immunity not established at dismissal stage |
Key Cases Cited
- Manuel v. City of Joliet, 903 F.3d 667 (7th Cir. 2018) (on remand holding Fourth Amendment claim for wrongful pretrial detention accrues when detention ends)
- Hurt v. Wise, 880 F.3d 831 (7th Cir. 2018) (disagreed-with and overruled to extent it treated pretrial-detention claims as due-process claims)
- Franks v. Delaware, 438 U.S. 154 (officer’s knowing or reckless falsehoods can invalidate a judicial probable-cause finding)
- Brendlin v. California, 551 U.S. 249 (defining seizure and when a person is not free to leave)
- Wallace v. Kato, 549 U.S. 384 (federal law governs accrual of § 1983 claims; statute of limitations borrows state personal-injury period)
- Preiser v. Rodriguez, 411 U.S. 475 (limitations on suing while custody continues)
- Heck v. Humphrey, 512 U.S. 477 (constraints on damages actions that would impugn conviction/duration of confinement)
- Avery v. City of Milwaukee, 847 F.3d 433 (convictions based on fabricated evidence violate due process)