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SUPREMES BRING 7TH CIRCUIT INTO LINE WITH EVERYONE ELSE; LEGAL COMMUNITY YAWNS
Earlier this week, the Supreme Court ruled that a man who spent 48 days in jail on charges fabricated by the police could sue under the 4th Amendment for an unreasonable seizure, that being the seven weeks he spent in stir.
Elijah Manuel was riding in a car pulled over for a turn-signal violation. He complained that the Joliet, Illinois, police beat him and called his racial epithets. The police found a vitamin bottle containing pills (amazing thing, that). When field tested, the pills were found to be negative for illegal drugs, but that didn’t stop the officers from claiming the pills were Ecstasy and arresting Elijah anyway.
The pills tested negative again at the station, but the police report falsely said otherwise. A magistrate found probable cause, and kept Elijah locked up. A short while later, a grand jury – relying on the false police reports and testimony – indicted him.
Eventually, the state crime lab report came back reporting the pills were vitamins. Even then, it took a few weeks for the district attorney to dismiss charges and set Elijah free.
The issue before the Supreme Court was whether a claim for malicious prosecution could be brought under the 4th Amendment even after “legal process” – that being the magistrate’s finding of probable cause – issued. The 7th Circuit said it could not be: once legal process issued, such a complaint had to be brought under the 5th Amendment.
In the event readers wonder why we don’t always report on Supreme Court cases like this one, the reason is this: Ten out of 12 federal circuits already held that Elijah’s 4th Amendment claim worked even after legal process issued, and in fact, even after a grand jury indictment, because legal process, like the initial seizure at the time of arrest, is unreasonable if it is based on fabricated evidence. The 8th Circuit had never ruled on the issue, and the 7th Circuit – ruling in Elijah’s case – got it wrong. As far as significance, this case is a yawner.
The decision includes dissents by Alito and Thomas, as well as a number of subsidiary issues orbiting the majority opinion like a legal planetary system. The case only got to where it is today because Elijah waited to the very last minute to file the case, and in fact missed the deadline to sue for false arrest, but not to sue for continued detention. The Justices debate the proper starting point for calculating the statute of limitations, a debate that has a kind of number-of-angels-dancing-on-the-head-of-a-pin quality to it.
At most, Manuel v. Joliet provides a clear basis for an additional constitutional claim – the 4th Amendment – when someone is locked up on bogus charges. It does not, however, really plow much new ground.
Manuel v. Joliet, Case No. 14-9496 (Supreme Court, Mar. 21, 2017)
– Thomas L. Root