Thompson v. Clark
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Thompson v. Clark 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 Thompson v. Clark.
In Thompson v. Clark, the Supreme Court addressed whether a plaintiff must show an affirmative indication of innocence to claim malicious prosecution under the Fourth Amendment. The Court resolved a split among the Courts of Appeals, determining that a favorable termination does not require such an indication, only that the prosecution ended without a conviction. This decision impacts how malicious prosecution claims are evaluated under 42 U.S.C. § 1983.
Holding
The single most important “bottom line” of what the Court decided in Thompson v. Clark.
The Court held that to demonstrate a favorable termination for a Fourth Amendment claim under § 1983 for malicious prosecution, a plaintiff need only show that the prosecution ended without a conviction.
Constitutional Concepts
These are the Constitution-related themes that appear in Thompson v. Clark. Click a concept to see other cases that involve the same idea.
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Why Search and Seizure is relevant to Thompson v. Clark
The case involves a Fourth Amendment claim for malicious prosecution, which is directly related to the limits on searches, seizures, and warrants.
Syllabus excerpt (verbatim)To maintain that Fourth Amendment claim under § 1983, a plaintiff such as Thompson must demonstrate, among other things, that he obtained a favorable termination of the underlying criminal prosecution.
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Why Procedural Due Process is relevant to Thompson v. Clark
The case discusses the procedural requirements for a favorable termination in the context of a malicious prosecution claim, which relates to procedural due process.
Syllabus excerpt (verbatim)Questions concerning whether a criminal defendant was wrongly charged, or whether an individual may seek redress for a wrongful prosecution, cannot reasonably depend on whether the prosecutor or court happened to explain why charges were dismissed.
Key Quotes
Short excerpts from the syllabus in Thompson v. Clark that support the summary and concepts above.
A plaintiff need not show that the criminal prosecution ended with some affirmative indication of innocence.
A plaintiff need only show that his prosecution ended without a conviction.
Doing so is consistent with 'the values and purposes' of the Fourth Amendment.
