Oral Argument: Chiaverini v. City of Napoleon | Case No. 23-50 | Date Argued: 4/15/24 | Date Decided: 6/20/24

Oral Argument: Chiaverini v. City of Napoleon | Case No. 23-50 | Date Argued: 4/15/24 | Date Decided: 6/20/24

Link to Docket: Here.

Background:

To make out a Fourth Amendment malicious prosecution claim under 42 U.S.C. § 1983, a plaintiff must show that legal process was instituted without probable cause. Thompson v. Clark, 142 S. Ct. 1332, 1338 (2022). Under the charge-specific rule, a malicious prosecution claim can proceed as to a baseless criminal charge, even if other charges brought alongside the baseless charge are supported by probable cause. Under the "any-crime" rule, probable cause for even one charge defeats a plaintiff's malicious prosecution claims as to every other charge, including those lacking probable cause.

Question Presented: Whether Fourth Amendment malicious prosecution claims are governed by the charge-specific rule, as the Second, Third, and Eleventh circuits hold, or by the "any-crime" rule, as the Sixth Circuit holds.

Holding: Pursuant to the Fourth Amendment and traditional common-law practice, the presence of probable cause for one charge in a criminal proceeding does not categorically defeat a Fourth Amendment malicious-prosecution claim relating to another, baseless charge.

Result: Vacated and remanded.

Voting Breakdown: 6-3. Justice Kagan delivered the opinion of the Court, in which Chief Justice Roberts and Justices Sotomayor, Kavanaugh, Barrett, and Jackson joined. Justice Thomas filed a dissenting opinion, in which Justice Alito joined. Justice Gorsuch filed a dissenting opinion.

Link to Opinion: Here.

Oral Advocates:

• For Petitioner: Easha Anand, Stanford, Cal.
• For United States, as Amicus Curiae: Vivek Suri, Assistant to the Solicitor General, Department of Justice, Washington, D.C.
• For Respondents: Megan M. Wold, Washington, D.C.