Byline: Derek Hawkins
7th Circuit Court of Appeals
Case Name: Maurice Lewis v. City of Chicago, et al.
Case No.: 17-1510
Officials: RIPPLE, SYKES, and BARRETT, Circuit Judges.
Focus: 4th Amendment Violation
Maurice Lewis spent more than two years in pretrial detention in the Cook County Jail based on police reports falsely implicating him for unlawfully possessing a firearm. After the charges against him were dropped, Lewis sued the City of Chicago and six police officers under 42 U.S.C. 1983 seeking damages for violation of his rights under the Fourth Amendment and the Due Process Clause of the Fourteenth Amendment.
The district court dismissed the suit, ruling that both claims were time-barred. Lewis appealed. Twelve days later the Supreme Court decided Manuel v. City of Joliet ("Manuel I"), 137 S. Ct. 911, 920 (2017), clarifying that detention without probable cause violates the Fourth Amendment "when it precedes, but also when it follows, the start of legal process in a criminal case." Id. at 918. The Court declined to decide when such claims accrue, instead remanding the case to this court to resolve that issue. Id. at 922. In September the Manuel panel held that a Fourth Amendment claim for wrongful pretrial detention accrues on the date the detention ends. Manuel v. City of Joliet ("Manuel II"), 903 F.3d 667, 670 (7th Cir. 2018).
The due-process claim is...