Chiaverini v. City of Napoleon
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Chiaverini v. City of Napoleon 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 Chiaverini v. City of Napoleon.
The Supreme Court addressed a Fourth Amendment malicious-prosecution claim involving Jascha Chiaverini, who was charged with multiple offenses by police officers in Napoleon, Ohio. The Court vacated the Sixth Circuit's decision, which held that probable cause for one charge invalidates a malicious-prosecution claim for another baseless charge. The case was remanded for further consideration on the causation element of the claim.
Holding
The single most important “bottom line” of what the Court decided in Chiaverini v. City of Napoleon.
The Court held that the presence of probable cause for one charge does not categorically defeat a Fourth Amendment malicious-prosecution claim related to another baseless charge.
Constitutional Concepts
These are the Constitution-related themes that appear in Chiaverini v. City of Napoleon. Click a concept to see other cases that involve the same idea.
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Why Search and Seizure is relevant to Chiaverini v. City of Napoleon
The case revolves around a Fourth Amendment malicious-prosecution claim, which is directly related to unreasonable seizures.
Syllabus excerpt (verbatim)Under the Fourth Amendment, a pretrial detention counts as an unreasonable seizure, and so is illegal, unless it is based on probable cause.
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Why Procedural Due Process is relevant to Chiaverini v. City of Napoleon
The case involves the procedural aspect of whether the charges were brought with probable cause, affecting the legality of the detention.
Syllabus excerpt (verbatim)A Fourth Amendment malicious-prosecution suit depends not just on an unsupported charge, but on that charge's causing a seizure—like the arrest and three-day detention here.
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Why Judicial Review is relevant to Chiaverini v. City of Napoleon
The Court's decision involves reviewing the Sixth Circuit's interpretation of the Fourth Amendment in the context of malicious prosecution.
Syllabus excerpt (verbatim)These uncontested points suffice to doom the Sixth Circuit's categorical rule barring a Fourth Amendment malicious-prosecution claim if any charge is valid.
Key Quotes
Short excerpts from the syllabus in Chiaverini v. City of Napoleon that support the summary and concepts above.
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.
A pretrial detention counts as an unreasonable seizure, and so is illegal, unless it is based on probable cause.
These uncontested points suffce to doom the Sixth Circuit's categorical rule barring a Fourth Amendment malicious-prosecution claim if any charge is valid.
