According to a lawsuit field by Elijah Manuel, police officers in Joliet, Illinois arrested him for no valid reason. Mr. Manuel claims that the police searched him and found a bottle of vitamins. The police performed a preliminary field test indicating that the pills were not illegal drugs. Nevertheless, they believed the pills contained ecstasy and arrested Mr. Manuel. At the police station, an evidence technician tested the pills again, and again got a negative result for drugs. However, the police officer lied and said one of the pills tested positive for ecstasy. The police then field an affidavit falsely claiming that Mr. Manuel possessed ecstasy, and a judge ordered him detained.
While Mr. Manuel sat in jail, the Illinois police laboratory conducted a scientific test. The test showed that the pills were not illegal drugs. Nevertheless, Mr. Manuel continued to sit in jail for a total of forty-eight days before the authorities finally released him.
Fourth Amendment Violation
The case went all the way to the United States Supreme Court, which faced two issues. The first was whether Mr. Manuel had a legitimate claim under the Fourth Amendment. This famous provision of the Constitution protects individuals from “unreasonable searches and seizures”. According to the lower court’s decision, the Fourth Amendment only applies when the police arrest a defendant. The lower court held that it does not apply after the court orders the defendant detained. The Supreme Court disagreed with this assessment and held that the Fourth Amendment continues to apply after court-ordered detention.
Did the Plaintiff File the Lawsuit in Time?
The second issue is more thorny. The statute of limitations requires that the plaintiff file this type of lawsuit within two years. Mr. Manuel filed this lawsuit more than two years after the police arrested him. However, he filed it less than two years after the court dismissed his criminal charges. He argued that his lawsuit was within the filing deadline. His theory was that he did not have a legitimate claim, and so the clock on his filing deadline did not start ticking, until the court dismissed his criminal charges. The police, on the other hand, claimed he had a case as soon as they arrested him. So they argued the clock on the filing deadline started then.
The Supreme Court did not decide this issue. The lower court wrongly decided that Mr. Manuel did not have a case at all. Therefore, the lower court never considered whether he filed within the correct statute of limitations. The Supreme Court said, “we are a court of review, not first review”. This means the Supreme Court will only review a decision by another court. The Supreme Court will not make make the first decision.
Don’t Waive Any Important Rights
There a couple of practical lessons we can draw from this case. The first is that, if you think you have a case, don’t leave it to right before the filing deadline to file a lawsuit. Filing deadlines can be tricky so leave plenty of cushion for error or alternative interpretation.
The second lesson, mostly for lawyers, is to always make every possible argument to the court you are in front of. An appellate court will only review an argument already made to the lower court it is reviewing. If you do not make an argument to the lower court, you waive that argument on appeal.