{"id":26374,"date":"2017-03-21T12:39:41","date_gmt":"2017-03-21T17:39:41","guid":{"rendered":"http:\/\/fourthamendment.com\/?p=26374"},"modified":"2017-03-22T05:45:56","modified_gmt":"2017-03-22T10:45:56","slug":"scotus-manuel-v-city-of-joliet-pretrial-detention-is-governed-by-the-fourth-amendment-especially-when-the-probable-cause-for-detention-is-on-fabricated-evidence","status":"publish","type":"post","link":"https:\/\/fourthamendment.com\/?p=26374","title":{"rendered":"SCOTUS: Manuel v. City of Joliet: Pretrial detention is governed by the Fourth Amendment, especially when the probable cause for detention is on fabricated evidence"},"content":{"rendered":"

Manuel v. City of Joliet<\/a>, 2017 U.S. LEXIS 2021 (U.S. March 21, 2017).<\/p>\n

SCOTUSBlog: Opinion analysis: The Fourth Amendment governs unlawful pretrial detention claims even after legal process begins; everything else is remanded<\/a> by Rory Little<\/p>\n

Syllabus:
\n
\nDuring a traffic stop, police officers in Joliet, Illinois, searched petitioner Elijah Manuel and found a vitamin bottle containing pills. Suspecting the pills to be illegal drugs, the officers conducted a field test, which came back negative for any controlled substance. Still, they arrested Manuel and took him to the police station. There, an evidence technician tested the pills and got the same negative result, but claimed in his report that one of the pills tested \u201cpositive for the probable presence of ecstasy.\u201d App. 92. An arresting officer also reported that, based on his \u201ctraining and experience,\u201d he \u201cknew the pills to be ecstasy.\u201d Id., at 91. On the basis of those false statements, another officer filed a sworn complaint charging Manuel with unlawful possession of a controlled substance. Relying exclusively on that complaint, a county court judge found probable cause to detain Manuel pending trial.<\/p>\n

While Manuel was in jail, the Illinois police laboratory tested the seized pills and reported that they contained no controlled substances. But Manuel remained in custody, spending a total of 48 days in pretrial detention. More than two years after his arrest, but less than two years after his criminal case was dismissed, Manuel filed a 42 U.S.C. \u00a7 1983 lawsuit against Joliet and several of its police officers (collectively, the City), alleging that his arrest and detention violated the Fourth Amendment. The District Court dismissed Manuel\u2019s suit, holding, first, that the applicable two-year statute of limitations barred his unlawful arrest claim, and, second, that under binding Circuit precedent, pretrial detention following the start of legal process (here, the judge\u2019s probable-cause determination) could not give rise to a Fourth Amendment claim. Manuel appealed the dismissal of his unlawful detention claim; the Seventh Circuit affirmed. <\/p>\n

Held:<\/em>
\n1. Manuel may challenge his pretrial detention on Fourth Amendment grounds. This conclusion follows from the Court\u2019s settled precedent. In Gerstein v. Pugh, 420 U.S. 103, the Court decided that a pretrial detention challenge was governed by the Fourth Amendment, noting that the Fourth Amendment establishes the minimum constitutional \u201cstandards and procedures\u201d not just for arrest but also for \u201cdetention,\u201d id., at 111, and \u201calways has been thought to define\u201d the appropriate process \u201cfor seizures of person[s] … in criminal cases, including the detention of suspects pending trial,\u201d id., at 125, n. 27. And in Albright v. Oliver, 510 U.S. 266, a majority of the Court again looked to the Fourth Amendment to assess pretrial restraints on liberty. Relying on Gerstein, the plurality reiterated that the Fourth Amendment is the \u201crelevan[t]\u201d constitutional provision to assess the \u201cdeprivations of liberty that go hand in hand with criminal prosecutions.\u201d Id., at 274; see id., at 290 (Souter, J., concurring in judgment) (\u201c[R]ules of recovery for such harms have naturally coalesced under the Fourth Amendment\u201d). That the pretrial restraints in Albright arose pursuant to legal process made no difference, given that they were allegedly unsupported by probable cause. <\/p>\n

As reflected in those cases, pretrial detention can violate the Fourth Amendment not only when it precedes, but also when it follows, the start of legal process. The Fourth Amendment prohibits government officials from detaining a person absent probable cause. And where legal process has gone forward, but has done nothing to satisfy the probable-cause requirement, it cannot extinguish a detainee\u2019s Fourth Amendment claim. That was the case here: Because the judge\u2019s determination of probable cause was based solely on fabricated evidence, it did not expunge Manuel\u2019s Fourth Amendment claim. For that reason, Manuel stated a Fourth Amendment claim when he sought relief not merely for his arrest, but also for his pretrial detention. Pp. 6\u201310.<\/p>\n

2. On remand, the Seventh Circuit should determine the claim\u2019s accrual date, unless it finds that the City has previously waived its timeliness argument. In doing so, the court should look to the common law of torts for guidance, Carey v. Piphus, 435 U.S. 247, 257\u2013258, while also closely attending to the values and purposes of the constitutional right at issue. The court may also consider any other still-live issues relating to the elements of and rules applicable to Manuel\u2019s Fourth Amendment claim. Pp. 11\u201315.<\/p>\n

590 Fed. Appx. 641, reversed and remanded.<\/p>\n

KAGAN, J., delivered the opinion of the Court, in which ROBERTS, C. J., and KENNEDY, GINSBURG, BREYER, and SOTOMAYOR, JJ., joined. THOMAS, J., filed a dissenting opinion. ALITO, J., filed a dissenting opinion, in which THOMAS, J., joined. <\/p>\n","protected":false},"excerpt":{"rendered":"

Manuel v. City of Joliet, 2017 U.S. LEXIS 2021 (U.S. March 21, 2017). SCOTUSBlog: Opinion analysis: The Fourth Amendment governs unlawful pretrial detention claims even after legal process begins; everything else is remanded by Rory Little Syllabus:<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-26374","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"_links":{"self":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/26374","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=26374"}],"version-history":[{"count":5,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/26374\/revisions"}],"predecessor-version":[{"id":26381,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=\/wp\/v2\/posts\/26374\/revisions\/26381"}],"wp:attachment":[{"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=26374"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=26374"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/fourthamendment.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=26374"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}