Term: 2016
Docket: 14-9496
Manuel v. City Of Joliet
- Pro
14-9496 MANUEL V. JOLIET, IL DECISION BELOW: 590 Fed. Appx. 641 CERT. GRANTED 1/15/2016 QUESTION PRESENTED: The question presented is whether an individual's Fourth Amendment right to be free from unreasonable seizure continues beyond legal process so as to allow a malicious prosecution claim based upon the Fourth Amendment. This question was raised, but left unanswered, by this Court in Albright v. Oliver, 510 U.S. 266 (1994). Since then, the First, Second, Third, Fourth, Fifth, Sixth, Ninth, Tenth, Eleventh, and D.C. Circuits have all held that a Fourth Amendment malicious prosecution claim is cognizable through 42 U.S.C. § 1983 ("Section 1983"). Only the Seventh Circuit holds that a Fourth Amendment Section 1983 malicious prosecution claim is not cognizable. LOWER COURT CASE NUMBER: 14-1581
In the case of Manuel v. City of Joliet, Elijah Manuel was arrested and charged with possession of a controlled substance after police officers found pills during a traffic stop. The laboratory results later revealed that the pills were not illegal substances but this information was not shared with prosecutors before his trial date. As such, he spent 48 days in jail awaiting trial for an offense he did not commit. After his release, Manuel filed a lawsuit against the city of Joliet and several police officers alleging violations to his Fourth Amendment rights - protection from unreasonable searches and seizures. The Supreme Court ruled in favor of Manuel stating that pretrial detention can violate the Fourth Amendment when it is unsupported by probable cause. This ruling allowed individuals like Mr.Manuel who are wrongfully held based on false evidence to seek redress under federal law even if their state criminal proceedings have ended.
In the dissenting opinion for Manuel v. City of Joliet, Justice Alito argued that the majority's decision was based on a misunderstanding of legal precedent and an incorrect interpretation of the Fourth Amendment. He contended that pretrial detention can only be challenged under due process grounds, not as a violation of unreasonable seizure protections in the Fourth Amendment. According to him, once a person is held by legal process following arrest, any unlawful detention claim becomes about whether there was probable cause for prosecution rather than arrest - which falls into due process territory. Furthermore, he expressed concern over potential implications this ruling could have on thousands of cases involving pretrial custody decisions and cautioned against expanding constitutional tort actions without clear guidance from historical understanding or legislative intent.
