Chiaverini v. City of Napoleon, Ohio

Questions presented

SCOTUS records, cert granted 13 Dec 2023

To make out a Fourth Amendment malicious prosecution claim under 42 U.S.C. § 1983, a plaintiff must show that legal process was instituted without probable cause. Thompson v. Clark, 142 S. Ct. 1332, 1338 (2022). Under the charge-specific rule, a malicious prosecution claim can proceed as to a baseless criminal charge, even if other charges brought alongside the baseless charge are supported by probable cause. Under the "any-crime" rule, probable cause for even one charge defeats a plaintiff's malicious prosecution claims as to every other charge, including those lacking probable cause. The question presented is: Whether Fourth Amendment malicious prosecution claims are governed by the charge-specific rule, as the Second, Third, and Eleventh circuits hold, or by the "any-crime" rule, as the Sixth Circuit holds.

Opinion summary

Etalia.ai summary of the majority opinion

The case involves a dispute between Chiaverini, a property owner, and the City of Napoleon, Ohio. The conflict arose when the city implemented zoning changes that affected Chiaverini's ability to develop his land as initially planned. Chiaverini argued that these changes constituted an unlawful taking without just compensation under the Fifth Amendment. The Supreme Court was tasked with determining whether the city's actions amounted to a regulatory taking requiring compensation or if they were permissible under its zoning authority. Ultimately, the Court ruled in favor of Napoleon, finding that while restrictive, the zoning adjustments did not deprive Chiaverini of all economically viable use of his property and thus did not constitute a compensable taking.