Chiaverini v. City of Napoleon, 602 U.S. ___ (2024)
This case involves a dispute between Jascha Chiaverini, a jewelry store owner, and police officers from Napoleon, Ohio. The officers charged Chiaverini with three crimes: receiving stolen property, dealing in precious metals without a license, both misdemeanors, and money laundering, a felony. After obtaining a warrant, the police arrested Chiaverini and detained him for three days. However, county prosecutors later dropped the case. Chiaverini, believing that his arrest and detention were unjustified, sued the officers, alleging a Fourth Amendment malicious-prosecution claim under 42 U.S.C. §1983. To win this claim, he had to show that the officers brought criminal charges against him without probable cause, leading to an unreasonable seizure of his person.
The District Court granted summary judgment to the officers, and the Court of Appeals for the Sixth Circuit affirmed. The Court of Appeals held that Chiaverini’s prosecution was supported by probable cause. In its decision, the court did not address whether the officers had probable cause to bring the money-laundering charge. The court believed that there was clearly probable cause to charge Chiaverini with the two misdemeanors. As long as one charge was supported by probable cause, it thought, a malicious-prosecution claim based on any other charge must fail.
The Supreme Court of the United States held that the presence of probable cause for one charge in a criminal proceeding does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another, baseless charge. The parties, and the United States as amicus curiae, all agreed with this conclusion, which follows from both the Fourth Amendment and traditional common-law practice. The Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion.
When a government official brings multiple charges, only one of which lacks probable cause, the valid charges do not insulate the official from a Fourth Amendment malicious-prosecution claim relating to the invalid charge.
SUPREME COURT OF THE UNITED STATES
Syllabus
CHIAVERINI et al. v. CITY OF NAPOLEON, OHIO, et al.
certiorari to the united states court of appeals for the sixth circuit
No. 23–50. Argued April 15, 2024—Decided June 20, 2024
This case involves a dispute between petitioner Jascha Chiaverini and police officers from Napoleon, Ohio. The officers charged Chiaverini, a jewelry store owner, with three crimes: receiving stolen property, a misdemeanor; dealing in precious metals without a license, also a misdemeanor; and money laundering, a felony. After obtaining a warrant, the police arrested Chiaverini and detained him for three days. But county prosecutors later dropped the case. Chiaverini, believing that his arrest and detention were unjustified, then sued the officers, alleging what is known as a Fourth Amendment malicious-prosecution claim under 42 U. S. C. §1983. To prevail on this claim, he had to show that the officers brought criminal charges against him without probable cause, leading to an unreasonable seizure of his person. The District Court, however, granted summary judgment to the officers, and the Court of Appeals for the Sixth Circuit affirmed. The Court of Appeals held that Chiaverini’s prosecution was supported by probable cause. In holding this, the court did not address whether the officers had probable cause to bring the money-laundering charge. In its view, there was clearly probable cause to charge Chiaverini with the two misdemeanors. And so long as one charge was supported by probable cause, it thought, a malicious-prosecution claim based on any other charge must fail.
Held: The presence of probable cause for one charge in a criminal proceeding does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another, baseless charge. The parties, and the United States as amicus curiae, all agree with this conclusion, which follows from both the Fourth Amendment and traditional common-law practice.
Under the Fourth Amendment, a pretrial detention counts as an unreasonable seizure, and so is illegal, unless it is based on probable cause. See Manuel v. Joliet, 580 U.S. 357, at 364–369. Even when a detention is justified at the outset, moreover, it may become unreasonably prolonged if the reason for it lapses. Rodriguez v. United States, 575 U. S., 348, 354–357. So if an invalid charge causes a detention to start or continue, then the Fourth Amendment is violated. Bringing the invalid charge alongside a valid one does not categorically preclude this possibility. As the starkest possible example, consider a person detained on a drug offense supported by probable cause and a gun offense that is not. If the prosecutor drops the gun charge, leaving the person in jail on the drug charge alone, then the baseless charge has caused a constitutional violation by unreasonably extending the detention. The person should not be categorically barred from bringing a Fourth Amendment malicious-prosecution claim just because the baseless charge was brought along with a good one.
The same conclusion follows from the common-law principles governing malicious-prosecution suits. This Court has analogized claims like Chiaverini’s to the common-law tort of malicious prosecution, and has explained that the tort can inform courts’ understanding of this type of claim. Thompson v. Clark, 596 U.S. 36, 43–44. A plaintiff bringing a common-law malicious-prosecution suit had to show that an official initiated a charge without probable cause. But he did not have to show that every charge brought against him lacked an adequate basis. See, e.g., Barron v. Mason, 31 Vt. 189, 198 (it was no “defen[s]e that there was probable cause for part of the prosecution”).
These uncontested points suffice to doom the Sixth Circuit’s categorical rule barring a Fourth Amendment malicious-prosecution claim if any charge is valid. Of course, a Fourth Amendment malicious-prosecution suit depends not just on an unsupported charge, but on that charge’s causing a seizure—like the arrest and three-day detention here. The parties and amicus curiae offer three different views of how that causation element is met when a valid charge is also in the picture. But this issue is not properly before the Court, so the Sixth Circuit should address it on remand. Pp. 4–8.
Vacated and remanded.
Kagan, J., delivered the opinion of the Court, in which Roberts, C. J., and Sotomayor, Kavanaugh, Barrett, and Jackson, JJ., joined. Thomas, J., filed a dissenting opinion, in which Alito, J., joined. Gorsuch, J., filed a dissenting opinion.
Judgment VACATED and case REMANDED. Kagan, J., delivered the opinion of the Court, in which Roberts, C. J., and Sotomayor, Kavanaugh, Barrett, and Jackson, JJ., joined. Thomas, J., filed a dissenting opinion, in which Alito, J., joined. Gorsuch, J., filed a dissenting opinion. |
Judgment VACATED and case REMANDED. Kagan, J., delivered the opinion of the Court, in which Roberts, C. J., and Sotomayor, Kavanaugh, Barrett, and Jackson, JJ., joined. Thomas, J., filed a dissenting opinion, in which Alito, J., joined. Gorsuch, J., filed a dissenting opinion. |
Argued. For petitioners: Easha Anand, Stanford, Cal. For United States, as amicus curiae: Vivek Suri, Assistant to the Solicitor General, Department of Justice, Washington, D. C. For respondents: Megan M. Wold, Washington, D. C. |
Reply of Jascha Chiaverini, et al. submitted. |
Reply of petitioner Jascha Chiaverini, et al. filed. (Distributed) |
CIRCULATED |
Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument GRANTED. |
Brief amici curiae of States of Iowa, Alabama, Arkansas, Florida, Georgia, Kansas, Idaho, Indiana, Kentucky, Louisiana, Montana, Nebraska, Ohio, Oklahoma, South Carolina, South Dakota, Tennessee, Texas, and Utah filed. |
Amicus brief of Local Government Legal Center, National League of Cities, National Association of Counties, and International Municipal Lawyers Association submitted. |
Amicus brief of States of Iowa, Alabama, Arkansas, Florida, Georgia, Kansas, Idaho, Indiana, Kentucky, Louisiana, Montana, Nebraska, Ohio, Oklahoma, South Carolina, South Dakota, Tennessee, Texas, and Utah submitted. |
Brief amici curiae of Local Government Legal Center, National League of Cities, National Association of Counties, and International Municipal Lawyers Association filed. |
Brief amici curiae of Local Government Legal Center, et al. filed. |
Brief amici curiae of States of Iowa, et al. filed. |
Motion of United States for leave to participate in oral argument and for divided argument submitted. |
Motion of the Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument filed. |
Brief of respondents Napoleon, OH, et al. filed. |
Brief of Napoleon, OH, et al. submitted. |
Record received electronically from the United States Court of Appeals for the Sixth Circuit and available with the Clerk. |
SET FOR ARGUMENT on Monday, April 15, 2024. |
Record requested from the United States Court of Appeals for the Sixth Circuit. |
Amicus brief of The Cato Institute submitted. |
Amicus brief of National Association of Criminal Defense Lawyers submitted. |
Amicus brief of Constitutional Accountability Center submitted. |
Amicus brief of United States submitted. |
Amicus brief of Institute for Justice submitted. |
Amicus brief of National Police Accountability Project submitted. |
Brief amicus curiae of Constitutional Accountability Center filed. |
Brief amicus curiae of National Police Accountability Project filed. |
Brief amicus curiae of Institute for Justice filed. |
Brief amicus curiae of The Cato Institute filed. |
Brief amicus curiae of United States filed. |
Brief amicus curiae of National Association of Criminal Defense Lawyers filed. |
Brief of Jascha Chiaverini, et al. submitted. |
Joint Appendix submitted. |
Joint appendix filed. (Statement of costs filed) |
Brief of petitioners Jascha Chiaverini, et al. filed. |
Motion for an extension of time to file the briefs on the merits filed. |
Motion to extend the time to file the briefs on the merits granted. The time to file the joint appendix and petitioners' brief on the merits is extended to and including January 31, 2024. The time to file respondents' brief on the merits is extended to and including March 5, 2024. |
Motion of Jascha Chiaverini, et al. for an extension of time submitted. |
Petition GRANTED. |
Rescheduled. |
DISTRIBUTED for Conference of 12/8/2023. |
DISTRIBUTED for Conference of 12/1/2023. |
Reply of petitioners Jascha Chiaverini, et al. filed. (Distributed) |
Brief of respondents Napoleon, OH, et al. in opposition filed. |
Motion to extend the time to file a response is granted and the time is further extended to and including October 20, 2023. |
Motion to extend the time to file a response from September 20, 2023 to October 20, 2023, submitted to The Clerk. |
Motion to extend the time to file a response is granted and the time is extended to and including September 20, 2023. |
Motion to extend the time to file a response from August 21, 2023 to September 20, 2023, submitted to The Clerk. |
Brief amicus curiae of Institute for Justice filed. |
Petition for a writ of certiorari filed. (Response due August 21, 2023) |
Application (22A935) granted by Justice Kavanaugh extending the time to file until July 14, 2023. |
Application (22A935) to extend the time to file a petition for a writ of certiorari from May 16, 2023 to July 14, 2023, submitted to Justice Kavanaugh. |