Manuel v. Joliet,
580 U.S. ___ (2017)

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Justia Opinion Summary

During a traffic stop, officers searched Manuel and found a vitamin bottle containing pills. Suspecting the pills were illegal drugs, officers conducted a field test, which came back negative for any controlled substance. They arrested Manuel. At the police station, an evidence technician tested the pills and got a negative result, but claimed that one pill tested “positive for the probable presence of ecstasy.” An arresting officer reported that, based on his “training and experience,” he “knew the pills to be ecstasy.” Another officer charged Manuel with unlawful possession of a controlled substance. Relying exclusively on that complaint, a judge found probable cause to detain Manuel pending trial. The Illinois police laboratory tested the pills and reported that they contained no controlled substances. Manuel spent 48 days in pretrial detention. More than two years after his arrest, but less than two years after his case was dismissed, Manuel filed a 42 U.S.C. 1983 lawsuit against Joliet and the officers. The district court dismissed, holding that the two-year statute of limitations barred his unlawful arrest claim and that pretrial detention following the start of legal process could not give rise to a Fourth Amendment claim. The Seventh Circuit affirmed. The Supreme Court reversed. Pretrial detention can violate the Fourth Amendment when it precedes or when it follows, the start of the legal process. The Fourth Amendment prohibits government officials from detaining a person absent probable cause. Where legal process has begun but has done nothing to satisfy the probable-cause requirement, it cannot extinguish a detainee’s Fourth Amendment claim. Because the judge’s determination of probable cause was based solely on fabricated evidence, it did not expunge Manuel’s Fourth Amendment claim. On remand, the Seventh Circuit should determine the claim’s accrual date, unless it finds that the city waived its timeliness argument.

  • Syllabus  | 
  • Opinion (Elena Kagan)  | 
  • Dissent (Clarence Thomas)  | 
  • Dissent (Samuel A. Alito, Jr.)

NOTE: Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued.The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader.See United States v. Detroit Timber & Lumber Co., 200 U. S. 321 .

SUPREME COURT OF THE UNITED STATES

Syllabus

MANUEL v. CITY OF JOLIET, ILLINOIS, et al.

certiorari to the united states court of appeals for the seventh circuit

No. 14–9496. Argued October 5, 2016—Decided March 21, 2017

During a traffic stop, police officers in Joliet, Illinois, searched petitioner Elijah Manuel and found a vitamin bottle containing pills. Suspecting the pills to be illegal drugs, the officers conducted a field test, which came back negative for any controlled substance. Still, they arrested Manuel and took him to the police station. There, an evidence technician tested the pills and got the same negative result, but claimed in his report that one of the pills tested “positive for the probable presence of ecstasy.” App. 92. An arresting officer also reported that, based on his “training and experience,” he “knew the pills to be ecstasy.” Id., at 91. On the basis of those false statements, another officer filed a sworn complaint charging Manuel with unlawful possession of a controlled substance. Relying exclusively on that complaint, a county court judge found probable cause to detain Manuel pending trial.

While Manuel was in jail, the Illinois police laboratory tested the seized pills and reported that they contained no controlled substances. But Manuel remained in custody, spending a total of 48 days in pretrial detention. More than two years after his arrest, but less than two years after his criminal case was dismissed, Manuel filed a 42 U. S. C. §1983 lawsuit against Joliet and several of its police officers (collectively, the City), alleging that his arrest and detention violated the Fourth Amendment. The District Court dismissed Manuel’s suit, holding, first, that the applicable two-year statute of limitations barred his unlawful arrest claim, and, second, that under binding Circuit precedent, pretrial detention following the start of legal process (here, the judge’s probable-cause determination) could not give rise to a Fourth Amendment claim. Manuel appealed the dismissal of his unlawful detention claim; the Seventh Circuit affirmed.

Held:

1. Manuel may challenge his pretrial detention on Fourth Amendment grounds. This conclusion follows from the Court’s settled precedent. In Gerstein v. Pugh, 420 U. S. 103 , the Court decided that a pretrial detention challenge was governed by the Fourth Amendment, noting that the Fourth Amendment establishes the minimum constitutional “standards and procedures” not just for arrest but also for “detention,” id., at 111, and “always has been thought to define” the appropriate process “for seizures of person[s] . . . in criminal cases, including the detention of suspects pending trial,” id., at 125, n. 27. And in Albright v. Oliver, 510 U. S. 266 , a majority of the Court again looked to the Fourth Amendment to assess pretrial restraints on liberty. Relying on Gerstein, the plurality reiterated that the Fourth Amendment is the “relevan[t]” constitutional provision to assess the “deprivations of liberty that go hand in hand with criminal prosecutions.” Id., at 274; see id., at 290 (Souter, J., concurring in judgment) (“[R]ules of recovery for such harms have naturally coalesced under the Fourth Amendment”). That the pretrial restraints in Albright arose pursuant to legal process made no difference, given that they were allegedly unsupported by probable cause.

As reflected in those cases, pretrial detention can violate the Fourth Amendment not only when it precedes, but also when it follows, the start of legal process. The Fourth Amendment prohibits government officials from detaining a person absent probable cause. And where legal process has gone forward, but has done nothing to satisfy the probable-cause requirement, it cannot extinguish a detainee’s Fourth Amendment claim. That was the case here: Because the judge’s determination of probable cause was based solely on fabricated evidence, it did not expunge Manuel’s Fourth Amendment claim. For that reason, Manuel stated a Fourth Amendment claim when he sought relief not merely for his arrest, but also for his pretrial detention. Pp. 6–10.

2. On remand, the Seventh Circuit should determine the claim’s accrual date, unless it finds that the City has previously waived its timeliness argument. In doing so, the court should look to the common law of torts for guidance, Carey v. Piphus, 435 U. S. 247 –258, while also closely attending to the values and purposes of the constitutional right at issue. The court may also consider any other still-live issues relating to the elements of and rules applicable to Manuel’s Fourth Amendment claim. Pp. 11–15.

590 Fed. Appx. 641, reversed and remanded.

Kagan, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Ginsburg, Breyer, and Sotomayor, JJ., joined. Thomas, J., filed a dissenting opinion. Alito, J., filed a dissenting opinion, in which Thomas, J., joined.

Primary Holding

The Fourth Amendment prohibits pretrial detention without probable cause whether it occurs before or after the start of the legal process.

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