__ U.S. __ (2017), 14-9496, Manuel v. City of Joliet
|Citation:||__ U.S. __, 137 S.Ct. 911, 197 L.Ed.2d 312, 85 U.S.L.W. 4130, 26 Fla.L.Weekly Fed. S 476, 26 Fla.L.Weekly Fed. S 477|
|Opinion Judge:||Kagan, Justice|
|Party Name:||ELIJAH MANUEL, Petitioner v. CITY OF JOLIET, ILLINOIS, et al|
|Attorney:||Stanley B. Eisenhammer argued the cause for petitioner. Ilana H. Eisenstein argued the cause for the United States, as amicus curiae, by special leave of court. Michael A. Scodro argued the cause for respondents.|
|Judge Panel:||Kagan, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Ginsburg, Breyer, and Sotomayor, JJ., joined. Thomas, Justice dissenting.|
|Case Date:||March 21, 2017|
|Court:||United States Supreme Court|
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.” ... (see full summary)
Argued October 5, 2016
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SEVENTH CIRCUIT
[197 L.Ed.2d 316] 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.
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, 95 S.Ct. 854, 43 L.Ed.2d 54, 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, 95 S.Ct. 854, 43 L.Ed.2d 54, 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, 95 S.Ct. 854, 43 L.Ed.2d 54. And in Albright v. Oliver, 510 U.S. 266, 114 S.Ct. 807, 127 L.Ed.2d 114, 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, 114 S.Ct. 807, 127 L.Ed.2d 114; see id., at 290, 114 S.Ct. 807, 127 L.Ed.2d 114 (Souter, J., concurring in judgment) (" [R]ules of recovery for such harms have naturally coalesced under the Fourth Amendment" ). [197 L.Ed.2d 317] 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. ___ - ___, 197 L.Ed.2d, at 320-323.
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, 257-258, 98 S.Ct. 1042, 55 L.Ed.2d 252, 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. ___ - ___, 197 L.Ed.2d, at 323-326.
590 Fed.Appx. 641, reversed and remanded.
Stanley B. Eisenhammer argued the cause for petitioner.
Ilana H. Eisenstein argued the cause for the United States, as amicus curiae, by special leave of court.
Michael A. Scodro argued the cause for respondents.
Kagan, J., delivered the opinion of the Court, in which Roberts, C. J., and Kennedy, Ginsburg, Breyer, and Sotomayor, JJ., joined.
Petitioner Elijah Manuel was held in jail for some seven weeks after a judge relied on allegedly fabricated evidence to find probable cause that he had committed a crime. The primary question in this case is whether Manuel may bring a claim based on the Fourth Amendment to contest the legality of his pretrial confinement. Our answer follows from settled precedent. The Fourth Amendment, this Court has recognized, establishes " the standards and procedures" governing pretrial detention. See, e.g.,
Gerstein v. Pugh, 420 U.S. 103, 111, 95 S.Ct. 854, 43 L.Ed.2d 54 (1975). And those constitutional protections apply even after the start of " legal process" in a criminal case--here, that is, after the judge's determination of probable cause. See Albright v. Oliver, 510 U.S. 266, 274, 114 S.Ct. 807, 127 L.Ed.2d 114 (1994) (plurality opinion); id., at 290, 114 S.Ct. 807, 127 L.Ed.2d 114 (Souter, J., concurring in judgment). Accordingly, we hold today that Manuel may challenge his pretrial detention on the ground that it violated [197 L.Ed.2d 318] the Fourth Amendment (while we
leave all other issues, including one about that claim's timeliness, to the court below).
Shortly after midnight on March 18, 2011, Manuel was riding through Joliet, Illinois, in the passenger seat of a Dodge Charger, with his brother at the wheel. A pair of Joliet police officers pulled the car over when the driver failed to signal a turn. See App. 90. According to the complaint in this case, one of the officers dragged Manuel from the car, called him a racial slur, and kicked and punched him as he lay on the ground. See id., at 31-32, 63. 1 The policeman then searched Manuel and found a vitamin bottle containing pills. See id., at 64. Suspecting that the pills were actually illegal drugs, the officers conducted a field test of the bottle's contents. The test came back negative for any controlled substance, leaving the officers with no evidence that Manuel had committed a crime. See id., at 69. Still, the officers arrested Manuel and took him to the Joliet police station. See id., at 70.
There, an evidence technician tested the pills once again, and got the same (negative) result. See ibid. But the technician lied in his report, claiming that one of the pills was " found to be . . . positive for the probable presence of ecstasy." Id., at 92. Similarly, one of the arresting officers wrote in his report that " [f ]rom [ his] training and experience, [ he] knew the pills to be ecstasy." Id., at 91. On the basis of those statements, another officer swore out a criminal complaint against Manuel, charging him with unlawful possession of a controlled substance. See id., at 52-53.
Manuel was brought before a county court judge later that day for a determination of whether there was probable cause for the charge, as necessary for further detention. See Gerstein, 420 U.S. at 114, 95 S.Ct. 854, 43 L.Ed.2d 54 ( requiring a judicial finding of probable cause following a warrantless arrest to impose any significant pretrial restraint on liberty); Ill.Comp.Stat., ch. 725, § 5/109-1 (West 2010) (implementing that constitutional rule). The judge relied exclusively on the criminal complaint--which in turn relied exclusively on the police department's fabrications--to support a finding of...
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