CA6: “[I]t is objectively unreasonable to frame an inmate” for a crime he didn’t commit

Plaintiff alleged an Art. III “injury in fact” in his claim that he was framed for a crime he didn’t commit. “Because it is objectively unreasonable to frame an inmate, we reverse the district court’s judgment and hold that Price properly alleged that he suffered an injury-in-fact when government agents allegedly framed and maliciously prosecuted him for a crime that he did not commit.” Webb v. United States, 2015 U.S. App. LEXIS 10161 (6th Cir. June 17, 2015):

Price pleaded guilty to specific state-law drug and gun offenses and agreed to be imprisoned only for those offenses. To the extent that he forfeited any Fourth Amendment rights by pleading guilty, he did not forfeit his Fourth Amendment right to be free from imprisonment for unrelated crimes that he did not commit.

In addition to fugitives like Price, every inmate in state and federal prisons is serving a term of imprisonment following conviction for an offense. Under the district court’s reasoning, each of these inmates would also have forfeited all of his Fourth Amendment rights regarding false imprisonment and malicious prosecution, and the government would have free rein to frame any of them for any other crime. Neither precedent nor common sense supports this outcome. While inmates have a diminished expectation of privacy, see Bell v. Wolfish, 441 U.S. 520, 557, 99 S. Ct. 1861, 60 L. Ed. 2d 447 (1979), they retain their Fourth Amendment right to be free from searches and seizures that are objectively unreasonable in light of those diminished expectations. See, e.g., Cornwell v. Dahlberg, 963 F.2d 912, 916 (6th Cir. 1992). Because it is objectively unreasonable to frame an inmate, we reverse the district court’s judgment and hold that Price properly alleged that he suffered an injury-in-fact when government agents allegedly framed and maliciously prosecuted him for a crime that he did not commit.