The United States Supreme Court recently held that the Fourth Amendment allows unlawful pretrial detention claims to be brought under 42 U.S.C. § 1983, even if the detention occurs after the start of the legal process. Manuel v. City of Joliet, 85 U.S.L.W. 4130 (2017).
The petitioner, Elijah Manuel, was discovered to be in possession of a vitamin bottle containing pills, during a traffic stop by police officers in Joliet, Illinois. The pills consistently tested negative for any controlled substances, but the arresting officers still filed a sworn complaint charging Manuel with unlawful possession of a controlled substance and an evidence technician also incorrectly claimed in his report that one of the pills tested positive for the presence of ecstasy.
While in jail awaiting his pending trial, the Illinois police laboratory also tested the pills and found no illegal substances present. However, Manuel still remained in custody for another month thereafter, and spent a total of 48 days in jail pretrial. The charge was eventually dropped, and two years later Manuel filed a legal action under 42 U.S.C. § 1983 claiming that the City violated his Fourth Amendment rights by arresting him without any reason and then by detaining him based entirely on made up evidence.
The District Court dismissed the claims as being untimely filed, but also held that pretrial detention following the start of the legal process could not be the basis of a Fourth Amendment claim. Manuel appealed the dismissal of the unlawful detention claim, but the Court of Appeals for the Seventh Circuit affirmed dismissal of the claim. The Seventh Circuit, citing prior precedent, held that the complaint could not be brought under the Fourth Amendment, but in some states could have been brought as a Due Process violation.
The Supreme Court reversed the lower court’s decision and held that the Fourth Amendment allows claims to be brought for unlawful pretrial detention even beyond the start of the legal process. The Court held that pretrial detention without probable cause can violate the Fourth Amendment not only when it precedes, but also when it follows the start of the legal process in a criminal case. The Court remanded to the Seventh Circuit to determine whether the statute of limitations started when the petitioner was arrested, or on the date his criminal case was dismissed. Feel free to contact attorney Dan Downey at ddowney@fishelhass.com or (614) 221-1216 if you have any questions.