Quarles v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Quarles v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Quarles v. United States.
In Nieves v. Bartlett, the Supreme Court addressed whether probable cause defeats a First Amendment retaliatory arrest claim under 42 U.S.C. § 1983. The Court concluded that probable cause generally bars such claims unless the plaintiff can show that similarly situated individuals not engaged in the same protected speech were not arrested. This decision emphasizes the complexity of proving causation in retaliatory arrest cases.
Holding
The single most important “bottom line” of what the Court decided in Quarles v. United States.
The Court held that probable cause generally defeats a First Amendment retaliatory arrest claim, unless the plaintiff presents objective evidence of disparate treatment compared to similarly situated individuals.
Constitutional Concepts
These are the Constitution-related themes that appear in Quarles v. United States. Click a concept to see other cases that involve the same idea.
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Why Procedural Due Process is relevant to Quarles v. United States
The case involves the procedural aspects of removal jurisdiction, which relates to the fair process of determining which court has jurisdiction.
Syllabus excerpt (verbatim)Section 1441(a) does not permit removal by a third-party counterclaim defendant.
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Why State–Federal Power is relevant to Quarles v. United States
The case addresses the allocation of authority between state and federal courts regarding removal jurisdiction.
Syllabus excerpt (verbatim)The limits Congress has imposed on removal show that it did not intend to allow all defendants an unqualified right to remove.
Key Quotes
Short excerpts from the syllabus in Quarles v. United States that support the summary and concepts above.
"Section 1441(a) does not permit removal by a third-party counterclaim defendant."
"Section 1453(b) does not permit removal by a third-party counterclaim defendant."
"The Court held that probable cause generally defeats a First Amendment retaliatory arrest claim."
