Justices Affirm Pretrial Fourth Amendment Rights

(CN) – The Supreme Court ruled Tuesday that an Illinois man can sue for malicious prosecution over his pretrial detention after he was jailed for 48 days because police falsified his drug-test results.

“The Fourth Amendment prohibits government officials from detaining a person in the absence of probable cause,” Justice Elena Kagan said, writing for the court’s 6-2 majority. “That can happen when the police hold someone without any reason before the formal onset of a criminal proceeding. But it also can occur when legal process itself goes wrong – when, for example, a judge’s probable-cause determination is predicated solely on a police officer’s false statements.”

Elijah Manuel was arrested in March 2011 for possession with intent to distribute ecstasy after Joliet, Ill., police found a vitamin bottle on his person containing pills. A field test of the bottle’s contents came back negative for any illegal drugs.

But Manuel was arrested anyway, and an evidence technician allegedly lied in his report, claiming that one of the pills was an ecstasy tablet.

On this allegedly fabricated evidence, a judge found probable cause to suspect Manuel of drug possession, and sent him to jail to await trial.

A second lab report issued two weeks after his arrest again found that the pills contained no ecstasy, but Illinois still arraigned Manuel and made him sit in jail another month before dismissing the charges.

Since Manuel spent 48 days in lockup, he had to miss work and drop the college courses for which he had already paid.

Though Manuel filed a federal complaint against the city of Joliet and various officers, most of his civil rights claims brought in 2013 were deemed time barred.

Manuel did have a timely claim for malicious prosecution, but the trial court dismissed this count as well under the 2001 case Newsome v. McCabe, in which the Seventh Circuit ruled that a person cannot challenge their pretrial confinement under the Fourth Amendment. The Seventh Circuit affirmed the trial court’s dismissal of Manuel’s malicious prosecution claim.

Ten other federal appeals courts have taken the opposite view that the Fourth Amendment right to be free from seizure absent probable cause extends through the pretrial period.

The U.S. Supreme Court’s Tuesday opinion reversed the Seventh Circuit and issued a firm rebuke to the Chicago-based appeals court’s position on this issue.

“Contrary to the Seventh Circuit’s view, Manuel stated a Fourth Amendment claim when he sought relief not merely for his (pre-legal-process) arrest, but also for his (post-legal-process) pretrial detention,” Kagan said. (Parentheses in original.)

Chief Justice John Roberts and Justice Anthony Kennedy joined the court’s liberal wing in Tuesday’s decision.

“All that the judge had before him were police fabrications about the pills’ content. The judge’s order holding Manuel for trial therefore lacked any proper basis. And that means Manuel’s ensuing pretrial detention, no less than his original arrest, violated his Fourth Amendment rights,” the majority’s ruling states.

Justices Samuel Alito wrote a dissent, which Justice Clarence Thomas joined.

“The court stretches the concept of a seizure much too far,” Alito wrote.

He continued, “What is perhaps most remarkable about the court’s approach is that it entirely ignores the question that we agreed to decide, i.e., whether a claim of malicious prosecution may be brought under the Fourth Amendment. I would decide that question and hold that the Fourth Amendment cannot house any such claim.”

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