Manuel v. Joliet

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. View "Manuel v. Joliet" on Justia Law