In a win for the little guy, the United States Supreme Court issued a decision that will make it easier for people to sue law enforcement for bringing charges without probable cause. Last Thursday, the Court sided with a jeweler from Ohio, ruling that he could pursue a claim for “malicious prosecution” against the police who charged him with a felony crime without having probable cause.
The case sets a new standard across the country that will make it easier to hold police accountable for bringing charges willy-nilly. Let's take a look at the back story before we dive into the legal implications.
Stolen Ring Attracts Police
Jascha Chiaverini owned a jewelry store in Napoleon, Ohio. He bought a ring for $45 from a petty jewel thief, and the ring’s rightful owners found out. They asked Chiaverini to return it to them, but he refused, so they contacted the authorities.
Two police officers later showed up at the jewelry store and told Chiaverini to return the ring to its owners. But the jeweler also refused them, saying that he had just received a letter from the police department telling him he should retain the ring as evidence. Police at some point told Chiaverini (without an attorney present) that he would be treated as a victim of theft if he returned the jewelry to the couple.
When another officer confronted him the following day, Chiaverini suggested that he had been operating his store without a license. This interesting piece of information made the police turn their attention from the original ring theft to investigating Chiaverini’s business. A criminal proceeding was soon launched, with three complaints each charging a separate offense against the jeweler. Two were misdemeanors, one for receiving stolen property, the other for dealing in precious metals without a license. The third charge was for the felony of money laundering. The jeweler was arrested and detained for three days for the charges.
Jeweler Claims Probably No Cause
A warrant was issued for the jeweler’s arrest as a part of these proceedings. As you likely know, in the United States, arrests require probable cause (with some exceptions). This legal principle is rooted in the Fourth Amendment which protects against unreasonable searches and seizures. An arrest and detention of someone based on a criminal charge lacking probable cause is therefore a violation of the Constitution. To that end, states provide individuals who have been charged without probable cause to bring claims for “malicious prosecution.”
Chiaverini thought he was wrongly charged under this theory, and decided to bring a claim of malicious prosecution against Ohio law enforcement. The charges against him were later dropped because the prosecutors failed to bring the case to the grand jury in time, but the jeweler wanted to pursue the malicious prosecution claim anyway.
The Malicious Prosecution Suit
For the malicious prosecution lawsuit, Chiaverini had to show why the officers did not have probable cause to bring the arrest. When the officers had applied for an arrest warrant, they had to fill out an affidavit making the case for probable cause on all three charges.
The burden of proof for the felony money laundering charge was high and contained a “knowledge” requirement. To prove Chiaverini guilty, the prosecutor would have to show that he bought the jewelry knowing it was obtained illegally. Therefore, The officers would need to have shown in their application for the arrest warrant that he likely knew of the ring’s stolen status. But the jeweler claimed that he had admitted to knowing that the ring was stolen was “an out-and-out lie.” Thus, he claims that the officers had no reason to think he met the “knowledge” requirement to bring the money laundering charge.
There’s a second requirement that Chiaverini claimed that the officers didn’t meet in bringing the felony charge. According to his attorney, Ohio law requires that the object of the money laundering (here, the ring) is worth more than $1,000 (whether or not this is a correct interpretation of the state statute isn’t really important for SCOTUS). The ring that Chiaverini bought from the couple was valued at $350.
So, Chiaverini brought his suit based on this theory against the officers in federal court.
Dismissed Suit Saved by SCOTUS
But whether or not the jeweler could bring the lawsuit was contested in the courts. The district court dismissed the lawsuit because it decided that there was probable cause for all three charges.
The Sixth Circuit decided it didn’t matter whether there was probable cause for the felony charge or not, since there was clearly probable cause for the two misdemeanors. They said that so long as probable cause supports at least one charge against Chiaverini, then his malicious-prosecution claim based on other charges (like money laundering) fail. So, they agreed that he couldn’t bring the lawsuit.
The case made its way to the U.S. Supreme Court, which went the other way. They decided that a plaintiff doesn't have to show that every charge against him lacks probable cause in order to bring a malicious prosecution suit. Even just one bad charge paired with good ones was enough to satisfy the requirements to bring the suit.
Justices Disagree on Fourth Amendment
Writing for the majority, Justice Elena Kagan reasoned: “The inclusion of the baseless charge — though brought along with a good charge — has thus caused a constitutional violation, by unreasonably extending the pretrial detention.” She thus revived the case, meaning that Chiaverini can proceed with the originally dismissed lawsuit.
The dissenting Justices (Thomas, Alito, and Gorsuch) wrote to express that they didn’t think it was proper to analogize malicious prosecution claims to unreasonable search and seizure claims or base them on the Fourteenth Amendment. This is an issue all three have previously dissented on.
Regardless, the upshot is that the law of the land has shifted to make it easier for civilians charged with crimes to bring claims against officers that don't do a thorough job of vetting their warrants.
Related Resources:
- Malicious Prosecution (FindLaw's Learn About the Law)
- Fourth Amendment Protection Against Unreasonable Searches and Seizures (FindLaw's Learn About the Law)
- Unattended Change and 'Found Money' Theft (FindLaw's Learn About the Law)
