ELIJAH MANUEL v. CITY OF JOLIET, ILLINOIS
Supreme Court of the United States, Kagan, March 21, 2017,
Illegal Detention – A person held pending trial can sue for illegal detention if his arrest violated the 4th Amendment.

While Manuel sat in jail, the Illinois police laboratory reexamined the seized pills, and on April 1, it issued a report concluding (just as the prior two tests had) that they contained no controlled substances. See App. 51.
But for unknown reasons, the prosecution—and, critically for this case, Manuel’s detention—continued for more than another month. Only on May 4 did an Assistant State’s Attorney seek dismissal of the drug charge.

The danger in having people unfamiliar with the lay of the land draw the maps…

Facts
Officers in Joliet, Illinois arrested Manuel for a CDS violation despite a negative field test. Police chemists tested the “drugs” and found one of them tested positive, but a re-test showed them all to test negative.
Manuel was held for 48 days pending trial and his criminal case was eventually dismissed.
Manuel then filed suit, claiming that the officers lied when they claimed that the drugs were CDS and thus his arrest and 48 days of detention were illegal.
Law from the Case
Held: “Manuel’s ensuing pretrial detention, no less than his original arrest, violated his Fourth Amendment rights”
Detention- 4th Amendment – An individual cannot be significantly detained by the government without probable cause.
Detention- 4th Amendment – A person is detained without probable cause when their detention is based on false material statements. This includes false statements to a judicial officer determining probable cause.
Detention- 4th Amendment – The Fourth Amendment controls not only seizure of an individual, but their detention as well. This includes pre-trial detention.