Skip to main content

In a 6-2 decision, the United States Supreme Court held that the Fourth Amendment protects individuals from illegal pretrial detentions even after the arrest has been reviewed by a judge. HLERK attorneys Stanley Eisenhammer and Pam Simaga were appointed by the District Court to represent the Plaintiff, Elijah Manuel. They took his case to the U.S. Supreme Court and won despite having their arguments rejected by two lower courts.

In this case, the Plaintiff, Manuel, was arrested for possession of illegal drugs even though two drug tests administered by the police came back negative. Despite these negative drug tests, the police brought Manuel before a judge and testified that Manuel possessed illegal drugs. As a result, the county judge sent Manuel to jail to await trial.

After having sat in jail for two weeks, the State Police issued the results of its lab test which found no illegal drugs. Manuel, however, remained in jail for another month before the State’s Attorney moved for dismissal.  All told, Manuel spent 48 days behind bars.

After examining these facts, Justice Kagan, writing for the majority, held that “Manuel’s claim fits the Fourth Amendment, and the Fourth Amendment fits Manuel’s claim, as hand in glove.” In this instance, the county judge’s order holding Manuel, just like his initial arrest, violated the Fourth Amendment because it lacked any proper basis due to the police fabrication of evidence. Or as Justice Kagan put it:

“Legal process did not expunge Manuel’s Fourth Amendment
claim because the process he received failed to establish what
that Amendment makes essential for pretrial detention-probable
cause to believe he committed a crime.”

This decision, though favorable for Manuel, does not end Manuel’s search for justice. The Court remanded the case to the Seventh Circuit to decide whether Manuel’s claim is timely. Stan Eisenhammer and Pam Simaga will  represent him in the Seventh Circuit and will continue to do so until justice is served.

Contact Stan Eisenhammer and Pamela Simaga with your inquiries regarding the decision.