City of Joliet, Illinois, et al. v. Elijah Manuel

Manuel v. City of Joliet, 137 S. Ct. 911 (2017) (Manuel I), held that a 42 U.S.C. §1983 claim for unlawful post-process, pretrial detention is actionable as a Fourth Amendment tort. But the then-eightmember Court declined to resolve the parties’ dispute over the accrual date for such a claim, although two Justices noted in dissent that they would have reached the accrual question and resolved it in the City’s favor. On remand, the Seventh Circuit announced a new Fourth Amendment accrual rule—based on the idea that a Fourth Amendment detention constitutes a continuing tort—in square conflict with the law in other circuits and, separately, in conflict with the rule embraced by the two Justices to reach the issue in Manuel I. The question presented is whether the Seventh Circuit erred in holding that a Fourth Amendment claim for unlawful post-process, pretrial detention brought pursuant to §1983 is subject to a special rule of delayed accrual, rather than the traditional rule under which a claim accrues when an injury first occurs—here, respondent’s first appearance in court, when a judge found probable cause for his pretrial detention based on an allegedly false criminal complaint.