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Chiaveriniv.City Of Napoleon

CourtSupreme Court of the United States
Docket No.23-50
DecidedJune 20, 2024
Reporter602 U.S. 556
JudgesSupreme Court of the United States
Tags
CivilCivil RightsConstitutional LawFourth AmendmentProbable CauseSummary JudgmentDissent
Case Summary

Police charged jewelry-store owner Jascha Chiaverini with receiving stolen property, an unlicensed-precious-metals offense, and money laundering, then detained him for three days before prosecutors dropped the case. Chiaverini sued the officers under federal civil-rights law, alleging a Fourth Amendment malicious-prosecution violation. The lower courts held that probable cause for one charge defeated the claim without examining probable cause for the money-laundering charge. The Supreme Court of the United States rejected that approach. It held that probable cause must be assessed charge by charge; probable cause supporting one offense does not automatically defeat a claim based on prosecution for another offense lacking probable cause. The Court vacated the judgment for the officers and remanded for further proceedings. A dissent argued that the Court’s federal rule was unnecessary and that state malicious-prosecution remedies were the more appropriate route.

Opinion

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