The Supreme Court has finally made it official: The Fourth Amendment prohibits unreasonable seizures, even if they happen after the legal process of a case has begun. The case, Manuel v. City of Joliet, was just released on March 21, 2017.
Because of the status of the case, the Supreme Court assumed that everything in Manuel’s complaint was true: He was the passenger in a car when it was pulled over by the police in Joliet, Illinois. He was dragged from the car, called a racial slur, and assaulted while he was on the ground. Despite a lack of probable cause, he was searched and police found a vial of pills, which they were convinced were ecstasy. Even though a field test came back negative, Manuel was arrested for drug possession.
At the police station, the pills were tested again. Even though the test came back negative, the technician reported that one was “positive for the probable presence of ecstasy.” One of the arresting officers agreed, saying that his “training and experience” taught him that the pills were ecstasy. Relying exclusively on these statements, the county judge determined that there had been probable cause to arrest Manuel, and he was held in jail to await trial.
Manuel spent 48 days in jail before the pills were tested – negative, again – and the prosecutor got around to dropping his case.
The Fourth Amendment prohibits unreasonable seizures, including those that are done without probable cause. These usually happen in the field, when police arrest someone they suspect of committing a crime. However, these unreasonable seizures can also happen after the legal process has begun, as when a neutral and detached magistrate – in Manuel’s case, the county judge – has determined that there was probable cause for the arrest based on fabricated evidence.
While the Supreme Court has said all of that before, not all of the federal appellate courts had been following their decision to the letter. Importantly for Manuel, the federal appellate court in charge of Illinois – the Seventh Circuit – had been insisting that pretrial detentions were fine. According to the Seventh Circuit, legal process alone – regardless of how erroneous it was – was enough to put the Fourth Amendment’s protections to bed. Of course, this notion led to some ridiculous results, including that someone arrested on a warrant – a form of legal process, because it came from a neutral and detached magistrate – could raise no Fourth Amendment defense.
Some cases from the Supreme Court are not meant to change the law. Instead, they’re meant to slap a lower federal court into compliance with earlier Supreme Court decisions. Manuel v. City of Joliet was one of these cases.
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