WASHINGTON (CN) — The high court ruled in favor of an Ohio jeweler on Thursday, finding he could advance a malicious prosecution claim against the police officers who charged him with felony money laundering without probable cause.
Although only one of the three charges against Jascha Chiaverini lacked probable cause, his claim cannot be struck down, the justices held in a 6-3 opinion.
Chiaverini faced criminal charges stemming from the purchase of a stolen ring and later statements to police in which he suggested he was operating the store without a license. Officials charged him with receiving stolen property and dealing in precious metals without a license, both misdemeanors, and money laundering, a felony.
He was detained for three days, after which he brought a malicious prosecution claim under the Fourth Amendment, arguing that the officers did not have probable cause for the money laundering charge.
Justice Elena Kagan wrote in the majority opinion that the Sixth Circuit Court of Appeals “stepped out on its own” when it ruled against Chiaverini, finding that the officers had probable cause for the misdemeanors despite not meeting the standard for the felony charge,
Under the Fourth Amendment, pretrial detention that's not based on probable cause counts as an unreasonable seizure, the Barack Obama appointee noted.
She posed a hypothetical: An individual is detained on two charges, a drug offense with probable cause and a gun offense “built on lies.” The drug offense, for whatever reason, is dropped, leaving the person in jail on the invalid gun charge.
“The inclusion of the baseless charge — though brought along with a good charge — has thus caused a constitutional violation, by unreasonably extending the pretrial detention,” Kagan wrote.
Further, she said, common law principles when the relevant civil rights code was enacted held that a plaintiff doesn't have to show every charge against him lacks probable cause. Rather, one bad charge, even if paired with good ones, was enough to satisfy the “without probable cause” element.
“All that dooms the Sixth Circuit’s categorical rule barring a Fourth Amendment malicious prosecution claim if any charge is valid,” Kagan said.
The justices vacated the appeals court decision and remanded the case.
After Chiaverini bought a ring and an earring in 2016 from a recurring customer, he received a calls from a couple asking about a stolen ring. He called the police for help and gave a statement to officers who concluded that the ring belonged to the couple. Officers then suggested to Chiaverini, without an attorney present, that he would be treated as a victim of theft if he returned the jewelry to the couple.
Chiaverini claims the officers altered his original statement to suggest that that the jeweler suspected his acquisition was the product of theft, then used the false claim in a probable cause affidavit, along with three criminal complaints for retaining stolen property, violating precious metals dealers licensing requirements and money laundering.
To prove the money laundering felony charge, officers had to show Chiaverini bought the jewelry knowing that it was obtained illegally. Ohio law also requires money laundering charges on transitions over $1,000; Chiaverini bought the ring and earring for $45 and the ring was valued at $350.
A judge authorized an arrest and search warrant for Chiaverini. Police seized other jewelry and three store computers during the search. Chiaverini was arrested and spent three days in jail.
Prosecutors later declined to present their case to a jury and all of his charges were dismissed.
Citing monetary and reputational damages, Chiaverini accused officers of violating his Fourth Amendment rights and filed a claim for malicious prosecution. The lower court and Sixth Circuit ruled against him, prompting his appeal to the U.S. Supreme Court. He argued that the appeals court incorrectly applied the any crime rule, which only requires probable cause for any charges, instead of the charge-specific rule, which requires probable cause for each charge.
Justice Clarence Thomas wrote a dissenting opinion on Thursday, joined by Justice Samuel Alito, to voice his disapproval of a 2022 Supreme Court decision Thompson v. Clark, that makes malicious-prosecution claims analogous to Fourth Amendment unreasonable-seizure claims.
“I would take a far simpler course,” the George H.W. Bush-appointed Thomas wrote. “Instead of forcing a square peg into a round hole by judging an unreasonable seizure based on the malicious prosecution tort, I would ‘hold that a malicious protection claim may not be brought under the Fourth Amendment.’”
In a separate dissent, Justice Neil Gorsuch, a Donald Trump appointee, also said malicious prosecution claims shouldn't be housed under the Fourth Amendment.
“Rather,” Gorsuch wrote, “it seems to me only that such a claim would be more properly housed in the Fourteenth Amendment.”
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