Civil rights lawsuit of Illinois man detained over bottle of vitamins can go forward, SCOTUS rules
An Illinois man jailed for about two months after police claimed he had Ecstasy, despite lab work that the pills tested negative for the illegal drug, can pursue his federal civil rights claim, the U.S. Supreme Court ruled Tuesday.
The opinion (PDF) sends Elijah Manuel’s unlawful detention claim back to the 7th U.S. Circuit Court of Appeals at Chicago, which previously dismissed the lawsuit, the Associated Press reports. He was stopped by Joliet, Illinois, police in 2011 and detained after a vitamin bottle with pills was found on his person.
Manuel, who is black, says he was arrested by officers after they pulled over the car his brother was driving. Manuel says an officer yanked him from the car, screamed a racial slur, pulled a bottle of vitamins from his pocket, and said their field tests indicated it was Ecstasy. Officers lied about the test, Manuel alleges, and lied when they said they smelled marijuana in the car.
A field test for controlled substances came back negative, according to the opinion, but police took Manuel to the police station. There, an evidence technician tested the pills and also got a negative result, with the exception of one pill that tested “positive for the probable presence of Ecstasy.”
Also, an officer who arrested Manuel stated that based on his “training and experience,” he “knew the pills to be Ecstasy.” Manuel was charged with unlawful possession of a controlled substance.
Based on “allegedly fabricated evidence”—according to Justice Elena Kagan, who wrote for the majority—a Will County Circuit Court judge found probable cause to detain Manuel pending trial.
The Illinois police laboratory found that the pill seized from Manuel contained no controlled substance. However, he remained in pretrial detention for 48 days, according to the opinion. The indictment was dismissed after prosecutors saw a police lab report that said the pills in question were vitamins.
Manuel filed a federal civil rights complaint more than two years after his arrest but less than two years from the time that charges against him were dismissed. The district court dismissed the claim, finding that a two-year statute of limitations barred his unlawful arrest claim, and pretrial detention following the judge’s probable cause determination can’t give rise to a Fourth Amendment claim. The 7th Circuit affirmed the ruling.
The Fourth Amendment prohibition of the government holding someone without probable cause can happen when the legal process goes wrong, Kagan wrote for the majority. Chief Justice John G. Roberts Jr. as well as Justices Anthony M. Kennedy, Ruth Bader Ginsburg, Stephen G. Breyer and Sonia Sotomayor joined the opinion.
“No evidence of Manuel’s criminality had come to light in between the roadside arrest and the county court proceeding initiating legal process; to the contrary, yet another test of Manuel’s pills had come back negative in that period,” according to the opinion. “All that the judge had before him were police fabrications about the pills’ content. The judge’s order holding Manuel for trial therefore lacked any proper basis. And that means Manuel’s ensuing pretrial detention, no less than his original arrest, violated his Fourth Amendment rights.”
Justice Samuel A. Alito Jr. wrote a dissent, which was joined by Justice Clarence Thomas, arguing that Manuel’s malicious prosecution claim should not be brought under the Fourth Amendment.
“A well-known medical maxim—‘first, do no harm’—is a good rule of thumb for courts as well. The court’s decision today violates that rule by avoiding the question presented in order to reach an unnecessary and tricky issue,” Alito wrote. “The resulting opinion will, I fear, inject much confusion into Fourth Amendment law. And it has the potential to do much harm—by dramatically expanding Fourth Amendment liability under Section 1983 in a way that does violence to the text of the Fourth Amendment.”