Manuel v. City of Joliet (U.S. Supreme Court)

Petitioner in this case sought damages under Section 1983 from the City of Joliet, alleging that several prolice officers violated his Fourth Amendment rights by using fabricated evidence to detain him pretrial. Petitioner argued that alleged police misstatements at his probable cause hearing stated a claim for “malicious prosecution” under the Fourth Amendment. Malicious prosecution claims at common law do not accrue unless and until the underlying prosecution ends favorably for the malicious-prosecution plaintiff. Petitioner contended that the Fourth Amendment claim did not accrue until prosecutors dropped the charges against him, making his constitutional malicious prosecution claim timely. Representing the respondent, we agreed that plaintiff stated a Fourth Amendment claim based on alleged misrepresentations at his probable cause hearing, but argued that it is wrong to import the favorable-termination element from common law malicious prosecution into the Fourth Amendment, which does not require victims of unlawful seizures to prove that their prosecutions concluded favorably.

The Supreme Court agreed that the petitioner had stated a Fourth Amendment claim by alleging misstatements at his probable cause hearing.  Because the Court read the court of appeals’ decision as disagreeing with that proposition, however, the Court remanded the case for the Court of Appeals to address the favorable-termination question in the first instance. The dissent maintained that the Court should have reached the disputed issue, rejected petitioner’s favorable-termination theory, and held his Fourth Amendment claim untimely.