A Technical Yet Important Victory for Civil Rights Plaintiffs
Just this past week, the U.S. Supreme Court ruled in the case of Manuel v. City of Joliet, that a criminal suspect who is arrested and detained absent probable cause, and whose pretrial detention lasts for several weeks before the prosecutor dismisses the case against him, has the right to bring a § 1983 claim based on a Fourth Amendment violation.
The Plaintiff in this case, Elijah Manuel (“Manuel), an Illinois resident, was a passenger in a vehicle that his brother was driving. After police stopped the vehicle for an alleged traffic violation, Manuel claimed that an officer dragged him from the vehicle, called him a racial slur, and then kicked and punched him while he laid on the ground. Officers then searched him and found a vitamin bottle containing pills. Officers believed that the pills were illegal drugs but field tests performed at the scene confirmed that the pills were not a controlled substance. Having no evidence at that point that Manuel had committed a crime, officers arrested him and took him to the police station anyway. At the station, an evidence technician tested the pills with the results again coming back negative. The technician, however, lied in his report and claimed that one pill tested positive for ecstasy. Based on this and another officer’s statement that he believed the pills were ecstasy, the prosecutor issued a complaint and formally charged Manuel with possession of a controlled substance. An Illinois judge reviewed the complaint, which was based on false evidence, and found probable cause to charge Manuel for the crime and to further detain him. The judge then sent Manuel to jail to await trial. Approximately two weeks later, the Illinois police laboratory tested the pills and issued a report concluding that the pills were not a controlled substance. Prosecutors ultimately dismissed the case against Manuel but only after he had spent approximately seven weeks in jail for having allegedly committed a crime that the state had no reasonable basis for believing he had committed.
Manuel sued the City of Joliet and the officers that arrested him claiming that they violated his Fourth Amendment right to be free from unreasonable searches and seizures, by arresting and detaining him for over seven weeks based on false evidence.
The City of Joliet sought to dismiss Manuel’s case on the grounds that his claim was not a valid Fourth Amendment claim, because the Fourth Amendment does not attach to claims where a person is detained after he or she appears before a judge. The City argued that the only proper claim Manuel could make under these facts was a due process claim, which required that Manual exhaust all Illinois remedies first before bringing his constitutional claim.
The Supreme Court rejected this argument and ruled that Manuel was right to bring a Fourth Amendment claim. The Court found that as long as the basis of Manuel’s claim was that he was arrested and detained by police absent probable cause, he could bring a §1983 action on the grounds that his Fourth Amendment’s rights had been violated.
This decision might seem technical but it extremely important for civil right plaintiffs. If the Court had ruled against Manuel on this issue, he would have been left with bringing a state law claim for malicious prosecution, a claim which many states have made exceedingly difficult for civil rights plaintiffs to recover under. In general, state legislatures have made it harder for civil rights plaintiffs to succeed on civil rights claims in state court by immunizing state governments for their conduct, imposing impractical notice requirements, capping damages for civil rights plaintiffs at low amounts, and refusing to allow for attorney fees for plaintiffs who win their cases. In short, federal courts, by and large, provide a more even playing field for civil rights plaintiffs alleging constitutional or federal law violations.
Thankfully, the Court’s decision keeps federal courts open for specific cases like Mr. Manuel’s. And for those of us who care deeply about justice for all citizens- no matter their creed, color or socioeconomic status- that is something we can all applaud.