Manuel v. City of Joliet - 137 S. Ct. 911 (2017)

Rule:

The Fourth Amendment establishes the standards and procedures governing pretrial detention. And those constitutional protections apply even after the start of “legal process” in a criminal case.

Facts:

During 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 “positive for the probable presence of ecstasy.” An arresting officer also reported that, based on his training and experience, he knew the pills to be ecstasy. 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. 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. §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's 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 could not give rise to a Fourth Amendment claim. Manuel appealed the dismissal of his unlawful detention claim.

Issue:

Could pretrial detention, which followed the start of legal process, give rise to a Fourth Amendment claim?

Answer:

Yes.

Conclusion:

The Court held that Manuel may challenge his pretrial detention on Fourth Amendment grounds. The Court noted that in Gerstein v. Pugh, 420 U. S. 103, 95 S. Ct. 854, 43 L. Ed. 2d 54, the Court decided that a pretrial detention challenge was governed by the Fourth Amendment, noting that the Fourth Amendment established the minimum constitutional standards and procedures not just for arrest but also for detention. According to the Court, pretrial detention can violate the Fourth Amendment not only when it preceded, but also when it followed, the start of legal process. The Court noted that the Fourth Amendment prohibited 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's Fourth Amendment claim. In this case, the Court held that since the judge's determination of probable cause was based solely on fabricated evidence, it did not expunge Manuel's Fourth Amendment claim. Accordingly, judgment of the lower court was reversed and the case was remanded. On remand, the lower court has to determine whether Manuel’s 42 U.S.C.S. § 1983 claim accrued for limitations purposes on the date legal process was initiated or on the date the criminal charges were dismissed.