Manuel v. City of Joliet Case Brief

Posted: November 1, 2016 by beguide in case summaries, Criminal Procedure, Fantasy Supreme Court League, search and seizure, Uncategorized, War on Drugs
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For every case on the podcast and in the Fantasy League, we will provide a brief summary of what to know and what to worry about.
WHAT HAPPENED: When you are a criminal defendant facing drug charges, your defenses to those charges often rank:
(1) contesting a search under the 4th Amendment
(2) disproving possession with factual evidence
(3) hoping for a mistake in the crime lab.
……
(Whatever last place is) alleging the police framed you and planted drugs on you.

This is not to say this never happens, but the defense itself is a Hail Mary before the Court and the Jury, as it is hard to prove and harder to believe. Within that context, consider the plight of Mr. Manuel, the plaintiff in this action. Manuel successfully alleged and proved that police officers arrested him for drugs, even though they knew he was only in possession of health supplements. Accordingly, Manuel is suing the City of Joliet for damages stemming from that arrest.

WHY IS THIS BEFORE THE SUPREME COURT:  This gets a little technical, but the basis of Manuel’s civil claim is a tort known as Malicious Prosecution.  Because of the nuances of Manuel’s criminal case, Manuel was barred from bringing the most common form of a Malicious Prosecution claim due to the Statute of Limitations. Instead, Manuel wants to bring a rarer Malicious Prosecution action which is pursuant to the 4th Amendment, because that claim has a longer Statute of Limitations.  Although many jurisdictions allow this type of claim, Manuel’s does not.

WHAT ARE THE RAMIFICATIONS: Let’s cover the more specific one first. While Manuel’s jurisdiction does not recognize this claim, all other jurisdictions do; so this is not out in left field. Plus, allowing this claim would presumably only extend then Statute of Limitations in a reasonable way, so it’s hard to see harm if SCOTUS wants to make a uniform rule for all federal jurisdictions. That being said, there’s also no harm in allowing different jurisdictions to set their own rules, and it’s hard to see a legal basis for the Court to decide that this issue warrants uniformity.  On a broader end, the entire judicial branch’s inability to ensure that police are held civilly and/or criminally liable for both willful and negligent actions has been a running subplot of 2016. This case won’t change any of those previous cases and nor will it open the door for immediate police accountability, but it’s a small step in the right direction.

ROOT FOR Manuel if you believe the facts of this case warrant the Court taking action away from individual jurisdictions.

ROOT FOR City of Joliet if you believe that jurisdictional sovereignty is worth letting cases like this pass without remedy.

PREDICTION – 6-2 in favor of the City.

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