Manuel v. Joliet

Manuel may challenge his pretrial detention on Fourth Amendment grounds. This conclusion follows from the Court’s settled precedent. In Gerstein v. Pugh, 420 U. S. 103, the Court decided that a pretrial detention challenge was governed by the Fourth Amendment, noting that the Fourth Amendment establishes the minimum constitutional “standards and procedures” not just for arrest but also for “detention,” id., at 111, and “always has been thought to define” the appropriate process “for seizures of person[s]... in criminal cases, including the detention of suspects pending trial,” id., at 125, n. 27. On remand, the Seventh Circuit should determine the claim’s accrual date, unless it finds that the City has previously waived its timeliness argument. In doing so, the court should look to the common law of torts for guidance, Carey v. Piphus, 435 U. S. 247, 257– 258, while also closely attending to the values and purposes of the constitutional right at issue. The court may also consider any other still-live issues relating to the elements of and rules applicable to Manuel’s Fourth Amendment claim. 641, reversed and remanded.

Result

Reversed

The Court relied on precedent that applies the Fourth Amendment’s protection against unreasonable seizures to pretrial detention as well as arrest. It told the Seventh Circuit to consider rules from civil-injury cases and the purpose of that right when deciding when Manuel’s claim began.

The Seventh Circuit must decide when Manuel’s claim began for filing-deadline purposes, unless the City had already given up that argument. It may also address other unresolved requirements for his claim.