County of Riverside v. McLaughlin
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500 U.S. 44 (1991)
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U.S. Supreme Court
County of Riverside v. McLaughlin, 500 U.S. 44 (1991)
County of Riverside v. McLaughlin
Argued Jan. 7, 1991
Decided May 13, 1991
500 U.S. 44
Respondent McLaughlin brought a class action seeking injunctive and declaratory relief under 42 U.S.C. § 1983, alleging that petitioner County of Riverside (County) violated the holding of Gerstein v. Pugh, 420 U. S. 103, by failing to provide "prompt" judicial determinations of probable cause to persons who, like himself, were arrested without a warrant. The County combines such determinations with arraignment procedures which, under County policy, must be conducted within two days of arrest, excluding weekends and holidays. The County moved to dismiss the complaint, asserting that McLaughlin lacked standing to bring the suit because the time for providing him a "prompt" probable cause determination had already passed and he had failed to show, as required by Los Angeles v. Lyons, 461 U. S. 95, that he would again be subject to the allegedly unconstitutional conduct. The District Court never explicitly ruled on the motion to dismiss, but accepted for filing a second amended complaint -- the operative pleading here -- which named respondents James, Simon, and Hyde as additional individual plaintiffs and class representatives, and alleged that each of them had been arrested without a warrant, had not received a prompt probable cause hearing, and was still in custody. The court granted class certification and subsequently issued a preliminary injunction requiring that all persons arrested by the County without a warrant be provided probable cause determinations within 36 hours of arrest, except in exigent circumstances.
The Court of Appeals affirmed, rejecting the County's Lyons-based standing argument and ruling on the merits that the County's practice was not in accord with Gerstein's promptness requirement because no more than 36 hours were needed to complete the administrative steps incident to arrest.
1. Plaintiffs have Article III standing. At the time the second amended complaint was filed, James, Simon, and Hyde satisfied the standing doctrine's core requirement that they allege personal injury fairly traceable to the County's allegedly unlawful conduct and likely to be redressed by the requested injunction. See, e.g., Allen v. Wright, 468 U. S. 737, 468 U. S. 751. Lyons, supra, distinguished. Although the named
plaintiffs' claims were subsequently rendered moot by their receipt of probable cause hearings or their release from custody, they preserved the merits of the controversy for this Court's review by obtaining class certification. See, e.g., Gerstein, 420 U.S. at 420 U. S. 110-111, n. 11. This Court is not deprived of jurisdiction by the fact that the class was not certified until after the named plaintiffs' claims became moot. Such claims are so inherently transitory, see, e.g., id. at 420 U. S. 110, n. 11, that the "relation back" doctrine is properly invoked to preserve the case's merits for judicial resolution, see, e.g., Swisher v. Brady, 438 U. S. 204, 438 U. S. 213-214, n. 11. Pp. 500 U. S. 50-52.
2. The County's current policy and practice do not comport fully with Gerstein's requirement of a "prompt" probable cause determination. Pp. 500 U. S. 52-59.
(a) Contrary to the Court of Appeals' construction, Gerstein implicitly recognized that the Fourth Amendment does not compel an immediate determination of probable cause upon completion of the administrative steps incident to arrest. In requiring that persons arrested without a warrant "promptly" be brought before a neutral magistrate for such a determination, 420 U.S. at 420 U. S. 114, 420 U. S. 125, Gerstein struck a balance between the rights of individuals and the realities of law enforcement. Id. at 420 U. S. 113. Gerstein makes clear that the Constitution does not impose on individual jurisdictions a rigid procedural framework for making the required determination, but allows them to choose to comply in different ways. Id. at 420 U. S. 123. In contrast, the Court of Appeals' approach permits no flexibility, and is in error. Pp. 500 U. S. 52-55.
(b) In order to satisfy Gerstein's promptness requirement, a jurisdiction that chooses to combine probable cause determinations with other pretrial proceedings must do so as soon as is reasonably feasible, but in no event later than 48 hours after arrest. Providing a probable cause determination within that time frame will, as a general matter, immunize such a jurisdiction from systemic challenges. Although a hearing within 48 hours may nonetheless violate Gerstein if the arrested individual can prove that his or her probable cause determination was delayed unreasonably, courts evaluating the reasonableness of a delay must allow a substantial degree of flexibility, taking into account the practical realities of pretrial procedures. Where an arrested individual does not receive a probable cause determination within 48 hours, the burden of proof shifts to the government to demonstrate the existence of a bona fide emergency or other extraordinary circumstance, which cannot include intervening weekends or the fact that, in a particular case, it may take longer to consolidate pretrial proceedings. Pp. 500 U. S. 55-58.
(c) Although the County is entitled to combine probable cause determinations with arraignments, it is not immune from systemic challenges
such as this class action. Its regular practice exceeds the constitutionally permissible 48-hour period because persons arrested on Thursdays may have to wait until the following Monday before receiving a probable cause determination, and the delay is even longer if there is an intervening holiday. Moreover, the lower courts, on remand, must determine whether the County's practice as to arrests that occur early in the week -- whereby arraignments usually take place on the last day possible -- is supported by legitimate reasons or constitutes delay for delay's sake. P. 500 U. S. 58-59.
888 F.2d 1276 (CA 9, 1989), vacated and remanded.
O'CONNOR, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and WHITE, KENNEDY, and SOUTER, JJ., joined. MARSHALL, J., filed a dissenting opinion, in which BLACKMUN and STEVENS, JJ., joined, post, p. 500 U. S. 59. SCALIA, J., filed a dissenting opinion, post, p. 500 U. S. 59