Seventh Circuit Rules that Pretrial Wrongful Detention Claim Accrues at the End of Detention

September 11, 2018

Previously, the U.S. Supreme Court ruled in Manuel v. City of Joliet, et al., No. 14-9496 (3/21/2017), that pretrial detainees may challenge the legality of their pretrial detentions under the Fourth Amendment after a probable cause determination has been made. The Supreme Court left unresolved the issue of whether Manuel’s claims were barred by the two-year statute of limitations and remanded the case to the Seventh Circuit Appellate Court for a decision on the issue.

The Seventh Circuit issued a decision this week on the statute of limitations issue. Manuel had sued the police after being arrested for possession of unlawful drugs on March 18, 2011. A judge decided that he would be held in jail pending trial on the same day but on May 4, 2011, the prosecutor dismissed the charges after it was determined that the pills Manuel had were legal. Manuel was released the following day. He was detained for a total of 47 days. Manuel filed suit on April 22, 2013.

The Court considered the possible dates for when Manuel’s claim accrued, or the statute of limitations began running. Defendant City argued that Manuel’s claim accrued when the judge held him pending trial and made a determination that there was probable cause to hold him. Manuel argued that the limitations clock started on May 4, 2011, when his position was vindicated by dismissal of the prosecution. The Court rejected both arguments and found that the clock started ticking on May 5, 2011, the day Manuel was released from pretrial detention. The Court reasoned that the wrong inflicted on Manuel was wrongful detention – that he was detained unlawfully without probable cause – and thus the period of limitations should depend on the dates of detention. This made Manuel’s claim timely, and therefore the Court remanded the case to the lower courts for Manuel’s claim to proceed.

Manuel v Joliet

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