In January 2014, four police officers and two EMTs arrived at Larry Thompson’s home in Brooklyn, New York, and demanded entry, allegedly in response to a 911 call accusing Thompson of abusing his one-week-old daughter. When Thompson refused to allow the police to enter his home without a warrant, police forced their way into the home, handcuffed Thompson, and charged him with obstructing governmental administration and resisting arrest. The EMTs took the newborn child to the hospital for an examination where medical professionals found no signs of abuse. Thompson remained in custody for two days. Prior to trial, the prosecutor moved to dismiss the charges without any explanation, and the case against Thompson was dismissed. Thompson, in turn, sued the police for malicious prosecution pursuant to Title 42, Section 1983 of the United States Code, which allows a person to seek redress when the government deprives him of his constitutional rights. Thompson claimed that the police officers subjected him to unlawful detention without probable cause in violation of his Fourth Amendment rights. However, because the prosecutor had dismissed the charges without explanation, both the trial court and the Second Circuit Court of Appeals ruled that Thompson’s criminal case did not affirmatively indicate his innocence, therefore his malicious prosecution claim against the police officers could not proceed.
On appeal, the U.S. Supreme Court reversed the lower court in a 6-3 ruling, finding that Thompson only needed to show that the criminal charges ended without a conviction, thus allowing his claim against the police officers for malicious prosecution to proceed. The Court stated that an “individual’s ability to seek redress for a wrongful prosecution cannot reasonably turn on the fortuity of whether the prosecutor or court happened to explain why the charges were dismissed.”
Marisa C. Maleck, Joshua N. Mitchell, and Edward A. Benoit of King & Spaulding LLP helped to advance the arguments in Thompson v. Clark. The brief and opinion are available at www.rutherford.org.
The Rutherford Institute, a nonprofit civil liberties organization, provides legal assistance at no charge to individuals whose constitutional rights have been threatened or violated, and educates the public on a wide spectrum of issues affecting their freedoms.
Source: https://bit.ly/3xJHbbO
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