Unlawful Pre-Trial Detention Claims Governed by Fourth Amendment
The Fourth Amendment governs a claim for unlawful pre-trial detention even beyond the start of legal process, the Supreme Court recently held in an opinion allowing a Section 1983 action to proceed against officers on grounds including the plaintiff’s pre-trial detention based on falsified evidence.
Shortly after midnight on March 18, 2011, Elijah Manuel was riding in the passenger seat of his brother’s car, through Joliet, Illinois. Two Joliet police officers pulled the car over when the driver failed to signal a turn.
According to Manuel’s subsequently filed complaint against the officers and the City of Joliet, the officers dragged Manuel from the car, called him a racial slur, and kicked and punched him as he lay on the ground. The officers then searched Manuel and found a vitamin bottle containing pills. Suspecting the pills were actually illegal drugs, the officers conducted a field test on them The test came back negative for any controlled substances. Regardless, the officers arrested Manuel and took him to the police station.
The pills tested negative again at the station. But the technician “lied in his report,” claiming the pills were found to be “positive for the probable presence of ecstasy.” And one of the arresting officers wrote in his wrote that “from his training and experience, he knew the pills to be ecstasy.” On the basis of those statements, another officer swore out a criminal complaint against Manuel, charging him with unlawful possession of a controlled substance.
Later that day, Manuel was brought before a county judge who relied exclusively on the criminal complaint (which relied exclusively on the police department’s fabrications) to support a finding of probable cause to continue Manuel’s detention. While Manuel sat in jail, the Illinois police laboratory reexamined the seized pills and issued a report concluding that the pills contained no controlled substances. One month later, the Assistant State’s Attorney sought and received dismissal of the drug charge against Manuel. In all, Manuel was detained for 48 days before his release.
Manuel subsequently filed a Section 1983 action against the officers who arrested him and the City of Joliet. He alleged the City violated his Fourth Amendment rights by arresting him at the roadside without any reason, and by “detaining him in police custody” for almost seven weeks “based entirely on made-up evidence.”
The federal district court dismissed Manuel’s suit, in part, because Seventh Circuit case law stated that pre-trial detention following the start of legal process was governed by the Due Process Clause of the Fourteenth Amendment, and not by the Fourth Amendment. The Seventh Circuit affirmed.
The Supreme Court of the United States, however, reversed the Seventh Circuit and held that “Manuel’s claim fits the Fourth Amendment, and the Fourth Amendment fits Manuel’s claim, as hand in glove.” The Fourth Amendment governs a claim for unlawful pre-trial detention, as it prohibits government officials from detaining a person in the absence of probable cause. In addition to taking place when police hold someone without reason before the formal onset of a criminal proceeding, “it can also occur when legal process itself goes wrong.” In Manuel’s case, that legal process went “wrong” when the county judge’s probable-cause determination was predicated solely on a police officer’s false statements.
Thus, the court permitted Manuel’s Fourth Amendment claim, that the legal process he received resulted in pre-trial detention unsupported by probable cause, could proceed.
Read the case: Manuel v. City of Joliet
This case law update was written by Michael J. Sgarlat, Associate Attorney, Shaw Bransford & Roth, PC.
For thirty years, Shaw Bransford & Roth P.C. has provided superior representation on a wide range of federal employment law issues, from representing federal employees nationwide in administrative investigations, disciplinary and performance actions, and Bivens lawsuits, to handling security clearance adjudications and employment discrimination cases.