[JURIST] The US Supreme Court [official website] ruled [opinion, PDF] Tuesday that Fourth Amendment [text] protections against unreasonable seizure can continue after the legal process has concluded. In Manuel v. City of Joliet [SCOTUSblog materials], the court reversed the lower court in a 6-2 decision. The case arose when police found a vitamin bottle containing pills when searching Elijah Manuel at a traffic stop. After a field test showed the pills were not a controlled substance, they arrested Manuel and brought him to the police station. The evidence statistician there received a negative result when testing the pills, but claimed one pill tested positive for the probable presence of ecstasy. The arresting officer stated in his report that he knew the pills were ecstasy. On this basis, Manuel was charged with unlawful possession of a controlled substance and a judge found probable cause to detain him pending trial. Later laboratory results definitively proved the pills were not ecstasy, but Manuel remained in custody for a total of 48 days of pretrial detention. Two years after his arrest, but less than two years after his case was dismissed, he filed a § 1983 [text] lawsuit against the City of Joliet, claiming his arrest violated the Fourth Amendment. The district court dismissed his claim in part because precedent held that pretrial detention following the start of legal process—here, the judge’s probable cause determination—cannot give rise to a Fourth Amendment claim. The US Court of Appeals for the Seventh Circuit [official website] had affirmed [opinion, PDF] the district court. Justice Elena Kagan wrote for the court:
The Fourth Amendment protects “[t]he right of the people to be secure in their persons … against unreasonable … seizures.” Manuel’s complaint seeks just that protection. Government officials, it recounts, detained—which is to say, “seiz[ed]”—Manuel for 48 days following his arrest. And that detention was “unreasonable,” the complaint continues, because it was based solely on false evidence, rather than supported by probable cause. By their respective terms, then, Manuel’s claim fits the Fourth Amendment, and the Fourth Amendment fits Manuel’s claim, as hand in glove.
The court recognized that the Fourth Amendment establishes the standards and procedures governing pretrial detention, and those constitutional protections apply even after the start of legal process in a criminal case.
The decision was 6-2, with Justice Clarence Thomas filing a dissenting opinion, and Justice Samuel Alito filing a dissenting opinion in which Thomas joined. The court heard arguments in the case in October after granting certiorari [JURIST reports] in January of last year.