A miscarriage of justice can unfold in a number of ways, but among the most appalling is fabricated evidence. Recently, the Supreme Court ruled in favor of a man entangled in a 2011 drug debacle in Illinois; the man was unjustly held in police custody for over a month and a half. The man's case tackled the questions of probable cause, the definition of pretrial confinement, and relief from malicious prosecution. Detainment with probable cause is increasingly murky; officers' assumptions and hasty conclusions often carry more weight than formal investigative procedures, at least at the outset of a case.
Justice Kagan penned the 6-2 majority opinion, writing “The Fourth Amendment prohibits government officials from detaining a person in the absence of probable cause… That can happen when the police hold someone without any reason before the formal onset of a criminal proceeding. But it also can occur when the legal process itself goes wrong – when, for example, a judge's probable-cause determination is predicated solely on a police officer's false statements.”
With ‘probable cause' apt to be misconstrued as we saw in this case, this court decision works to concretely define the boundaries of probable cause, eliminating any excessive leeway previously given to law enforcement and prosecutors. This will help the justice system to avoid cases such as this man's, where cloudy assumptions lead to wrongful detainment of innocent people.
The man, Elijah Manuel, was arrested in March 2011 for possession with intent to distribute ecstasy. Authorities tested the vitamin bottle found on Manuel's person. Field tests of the bottle's contents came back negative for illegal substances. An evidence technician allegedly lied in his report, claiming one pill within the bottle was an ecstasy tablet. The false report was deemed probable cause and Manuel was sent to jail where he awaited trial. A second lab test was performed, showing the bottle contained no ecstasy. Manuel was arraigned nevertheless and waited out one more month in jail before his eventual release. Manuel filed complaints against the city of Joliet, Illinois, only to be told they were time-barred. During his detainment, he was forced to miss work and drop college courses he had already paid for. 2001 case law determined that the claim of malicious prosecution he sought to bring forth would be dismissed. The Seventh Circuit court affirmed that decision, holding that pre-trial confinement could not be challenged under the Fourth Amendment.
The Supreme Court determined that the lower courts erred in their reading of the law, noting that Manuel sought relief not only for his "(pre-legal-process) arrest [which lower courts held could not be challenged], but also for his (post legal process) pretrial detention.” Justice Kagan stated, "The judge's order holding Manuel for trial therefore lacked any proper basis,” citing police fabrications. Manuel's Fourth Amendment rights were thereby violated. In the dissent, Justice Alito held that the Fourth Amendment could not house any claims for malicious prosecution. The Supreme Court's decision will allow Manuel to go forth and sue for malicious prosecution, marking a victory for who may be wrongfully detained, confront fabricated evidence, or face malicious prosecution.
Criminal charges are very complex in nature. Do not face them alone; allow a skilled criminal defense attorney to review the charges against you. If you have received criminal charges in the Seattle area, you will require an experienced Seattle criminal defense attorney. Contact the Law Offices of Steve Karimi as soon as possible to begin your free consultation.