City of New York, New York, et al. v. Jarrett Frost

In Manuel v. City of Joliet, 137 S. Ct. 911 (2017), this Court recognized that the Fourth Amendment, not the Due Process Clause, governs claims challenging pretrial detentions based on allegations of evidence fabrication. Here, however, despite rejecting a § 1983 plaintiff’s Fourth Amendment challenge to his pretrial detention because it was supported by probable cause, independent of the disputed evidence, a split panel of the U.S. Court of Appeals for the Second Circuit permitted him to pursue a due process-based claim challenging the same lawfully supported detention. The question presented is: Where a § 1983 plaintiff alleges that his pretrial detention was influenced by fabricated evidence, and the existence of probable cause independent of the challenged evidence defeats his Fourth Amendment claim, may he still pursue a due process-based claim based on alleged use of the same challenged evidence in securing the same pretrial detention?