Supreme Court of the United States
Elijah Manuel, Petitioner v. City of Joliet, Illinois
March 21, 2017580 U.S. 357
Summary
The Supreme Court held that Elijah Manuel may challenge his 48-day pretrial detention under the Fourth Amendment even though it followed the onset of legal process, because a probable-cause determination built solely on fabricated police statements did nothing to satisfy the probable-cause requirement and thus could not extinguish his Fourth Amendment claim or convert it into a due process claim. It reversed the Seventh Circuit, which had confined such claims to the Due Process Clause, and remanded for the lower court to decide the claim's accrual date (unless the City waived its timeliness argument), guided by common-law tort principles and the values of the constitutional right at issue. Justice Thomas filed a dissenting opinion, and Justice Alito filed a dissent joined by Thomas; they would have decided the question presented by holding that the Fourth Amendment cannot house a malicious prosecution claim, would have treated prolonged detention as something other than a continuing seizure, and would have affirmed on timeliness grounds.
Holding
- Whether a §1983 plaintiff may challenge pretrial detention that follows the start of legal process under the Fourth Amendment, where the probable-cause determination authorizing detention rested on fabricated evidence.. Yes. Pretrial detention can violate the Fourth Amendment not only when it precedes but also when it follows the start of legal process; where legal process has gone forward but has done nothing to satisfy the probable-cause requirement—as when a judge's probable-cause determination rests solely on fabricated evidence—it cannot extinguish the detainee's Fourth Amendment claim or convert it into a claim under the Due Process Clause.
- What should become of the parties' dispute over the accrual date of Manuel's Fourth Amendment detention claim.. Undecided and remanded: the Seventh Circuit should determine the claim's accrual date unless it finds that the City has previously waived its timeliness argument, looking to the common law of torts for guidance while closely attending to the values and purposes of the constitutional right at issue, and it may consider any other still-live issues relating to the elements of and rules applicable to the claim.
Docket 14–9496.