Chiaverini v. City of Napoleon, Ohio

The Supreme Court ruled that a person can sue for malicious prosecution even if some of the charges against them were valid. The Court rejected a lower court's rule that said a single valid charge automatically blocks a lawsuit regarding other baseless charges. Justice Elena Kagan explained that if an invalid charge causes someone to be detained, it violates the Fourth Amendment.

This decision makes it easier for individuals to hold officials accountable for bringing fake or unsupported charges. It ensures that police cannot hide behind one minor, valid charge to justify a much more serious, baseless one that keeps someone in jail. For example, a person charged with a valid minor traffic offense could still sue if they were also hit with a fake felony charge.

The case centers on the Fourth Amendment, which protects citizens from unreasonable searches and seizures. Historically, courts have looked at whether there was probable cause (a reasonable basis for suspicion) for each individual charge. This ruling aligns modern civil rights law with those historical common-law traditions.

The Court ruled 6-3 to vacate the lower court's decision, with Justice Kagan writing for a majority that included Chief Justice Roberts and Justices Sotomayor, Kavanaugh, Barrett, and Jackson. Justices Thomas, Alito, and Gorsuch dissented, arguing that the Fourth Amendment does not actually support this type of claim.

“A Fourth Amendment malicious prosecution claim can proceed even when a baseless charge is accompanied by a valid charge.”

“Nothing in the language of the Fourth Amendment supports a malicious prosecution claim.”

The Supreme Court held that valid criminal charges do not provide a 'get out of jail free' card for officials who also bring baseless ones.

The case now returns to the lower courts to determine if the specific baseless charge against Chiaverini actually caused him extra time in jail. Judges across the country will now have to evaluate malicious prosecution claims on a charge-by-charge basis rather than dismissing them entirely if one charge is valid.

The dispute was whether a person can sue for malicious prosecution when police combine valid charges with baseless ones. Chiaverini argued that a fake money-laundering charge caused him harm despite other valid misdemeanor charges.

Officers can no longer assume that one valid charge will protect them from lawsuits over other unsupported allegations. They must ensure every charge brought against a citizen is supported by probable cause (reasonable evidence).

The Court established that courts must evaluate malicious prosecution suits on a charge-by-charge basis. The presence of probable cause for one charge does not categorically defeat claims related to other baseless charges.

The case is vacated and remanded (sent back) to the lower court. That court must now decide if the baseless charge caused Chiaverini to be detained longer than the valid charges would have.

This ruling continues a trend of the Court looking at historical common law to define modern rights. It reinforces the idea that pretrial detention must always be justified by valid evidence for the specific crimes alleged.