Manuel v. City of Joliet, Illinois, et al.

Unlawful pretrial detention may be challenged on Fourth Amendment grounds, and not solely on the Due Process Clause.

Petitioner was held for 48 days pretrial based on evidence later found to be fabricated by the arresting officer. Two years after charges were dropped, Petitioner filed a §1983 action against the Respondent. Petitioner argued that Respondent violated his Fourth Amendment rights by arresting him without probable cause, and for unlawfully detaining him based on fabricated evidence. The district court dismissed Petitioner's claim finding that it was outside of the statute of limitations, and alternatively holding that pretrial detention is a legal process that must be challenged under the Due Process Clause. The Seventh Circuit Court of Appeals affirmed. The Supreme Court reversed, stating that the Fourth Amendment protects individuals from unreasonable seizures, and a seizure is reasonable only if it is based on probable cause. The Court further held that pretrial detention falls within the scope of the Fourth Amendment when the probable cause requirement is not satisfied, even if the evidence is found after the legal process begins. The Court remanded the case for further proceedings, leaving the lower court to review the Statute of Limitations dispute. REVERSED and REMANDED.