Chiaverini v. City of Napoleon
The Court ruled that having probable cause for one criminal charge does not automatically wipe out a civil-rights lawsuit over a different, baseless charge brought at the same time.
The decision means police cannot use a valid charge as a blanket shield against accountability for other charges they brought without adequate basis, though the lower court must still work out whether the disputed felony actually caused the jewelry store owner's arrest and detention.
How it got here: A federal trial court granted summary judgment to the officers; the Sixth Circuit affirmed, holding one valid charge barred any claim; the store owner asked the Supreme Court to step in, and the Court agreed to resolve a split among the federal appeals courts.
The Case in Depth
What happened
A jewelry store owner in Napoleon, Ohio, bought a ring for $45 that turned out to be stolen. After a dispute with police over returning it, officers charged him with two misdemeanors and a felony — money laundering — obtained a warrant, arrested him, and held him for three days. County prosecutors later dropped all charges without ever bringing the case to a grand jury. The store owner then sued the officers, arguing the felony charge was fabricated and lacked legal support.
The question before the Court
If police charge someone with both valid crimes and a baseless crime, can the person sue officers for the baseless charge even though the other charges were legitimate?
The Court's answer
No — the fact that some charges in a criminal proceeding are backed by probable cause does not automatically bar a civil-rights lawsuit over a different charge that was not. The Sixth Circuit had adopted a categorical rule: as long as one charge in a proceeding is valid, any claim about a baseless charge in the same case automatically fails. The Supreme Court unanimously rejected that rule on the merits, finding it inconsistent with both Fourth Amendment principles and the historical common law of malicious prosecution.
The Court sent the case back to the Sixth Circuit to tackle a harder follow-on question it left open: whether and how the allegedly baseless felony charge actually caused the store owner's arrest and three-day detention, given that valid misdemeanor charges were also present. Three different causation tests were proposed by the parties, but because the lower court never addressed the issue, the Supreme Court declined to resolve it.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
People arrested or detained on multiple charges — some with legal backing, some without — now have a clearer path to sue over the baseless ones. Officers and governments can no longer automatically defeat such lawsuits just by pointing to one solid charge in the same proceeding, meaning there is stronger incentive to justify every charge filed.
What changes now
The case returns to the Sixth Circuit, which must now decide whether the felony money-laundering charge — allegedly unsupported by probable cause — actually caused the store owner's arrest and three-day detention, even though valid misdemeanor charges were also filed. Three competing tests for answering that causation question were proposed by the parties; the lower court will need to pick one and apply it. This is a final merits ruling on the categorical-bar issue only.
What this does not decide
The Court explicitly left open how to determine whether an invalid charge actually caused a detention when valid charges were present too. Three competing tests — a "tainted warrant" approach, a but-for test, and a stricter legal-authorization test — were proposed but not resolved. Lower courts must work this out going forward.
Concurrences and dissents
Dissent — Justice Thomas
Justice Thomas, joined by Justice Alito, argued that a malicious-prosecution claim cannot properly be based on the Fourth Amendment at all. He contended that the Court's earlier decision in Thompson v. Clark — which created this type of claim — was wrongly decided, because malicious prosecution and an unreasonable seizure are fundamentally different wrongs with different elements. He would have simply affirmed the dismissal of the store owner's lawsuit, rather than sending it back for further proceedings under a flawed legal framework.
Dissent — Justice Gorsuch
“Stare for as long as you like at the Fourth Amendment and you won't see anything about prosecutions, malicious or otherwise.”Justice Gorsuch arguing that the Fourth Amendment has no natural connection to malicious-prosecution claims.
Justice Gorsuch dissented separately to argue that the Fourth Amendment — which guards against unreasonable searches and seizures — simply has nothing to do with prosecutions, malicious or otherwise. He suggested that if a constitutional hook exists for such a claim, it belongs under the Fourteenth Amendment's guarantee of due process, which actually focuses on judicial proceedings. He also noted that many states, including Ohio, already provide malicious-prosecution claims under state law that may be easier for plaintiffs to use.
How the Court got there
The legal reasoning, step by step
- The Court started from the settled Fourth Amendment rule that a pretrial detention must be backed by probable cause to be constitutional. A detention that begins or continues because of an invalid, unsupported charge is an unreasonable seizure — even if a valid charge was brought at the same time. The Court illustrated this with a hypothetical: if a prosecutor drops the valid charge, leaving a person jailed only on the baseless one, that baseless charge has plainly caused a constitutional violation.
- The Sixth Circuit's categorical rule — one valid charge insulates officers from any malicious-prosecution claim about every other charge — directly contradicted this Fourth Amendment framework. Because an invalid charge can independently cause or extend a detention, the fact that a valid charge was also filed is no automatic defense. Even the defendant police officers agreed with this conclusion by the time the case reached the Supreme Court.
- The Court reinforced its conclusion by looking at the historical common-law tort of malicious prosecution, which it had previously identified as the closest analog to this kind of civil-rights claim. Courts in the era when the relevant civil-rights law (42 U.S.C. § 1983) was enacted evaluated each charge separately. Groundless charges could support a lawsuit 'even if joined with good ones,' and probable cause for some charges was no defense to a suit over others that lacked it.
- With both Fourth Amendment doctrine and common-law history pointing the same way, the categorical Sixth Circuit rule had no foundation. The Court vacated it. It declined, however, to resolve a separate open question — how courts should determine whether an invalid charge actually caused the seizure when valid charges were also present — because that issue was not fully briefed, was not part of the question the Court agreed to hear, and had not been addressed below.
Doctrinal impact
Cases affected by this decision
Reaffirms Thompson v. Clark (596 U. S. 36)
The Court again builds on Thompson's recognition of a Fourth Amendment malicious-prosecution claim under § 1983.
Reaffirms Manuel v. Joliet (580 U. S. 357)
Applied Manuel's holding that pretrial detention without probable cause is an unreasonable seizure.