Chiaverini v. City of Napoleon, Ohio

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Supreme Court of the United States
Chiaverini v. City of Napoleon, Ohio
Term: 2023
Important Dates
Argued: April 15, 2024
Decided: June 20, 2024
Outcome
vacated and remanded
Vote
6-3
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh • Amy Coney Barrett • Ketanji Brown Jackson
Dissenting
Clarence Thomas • Samuel Alito • Neil Gorsuch

Chiaverini v. City of Napoleon, Ohio is a case that was decided by the Supreme Court of the United States on June 20, 2024, during the court's October 2023-2024 term. The case was argued before the Supreme Court of the United States on April 15, 2024. In a 6-3 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Sixth Circuit, holding that probable cause for one charge in a criminal proceeding does not categorically bar a Fourth Amendment malicious-prosecution claim regarding another unsubstantiated charge.[1]

HIGHLIGHTS
  • The issue: The case concerned malicious prosecution claims under the Fourth Amendment. Click here to learn more about the case's background.
  • The questions presented: "Whether Fourth Amendment malicious prosecution claims are governed by the charge-specific rule, as the Second, Third, and Eleventh circuits hold, or by the "any-crime" rule, as the Sixth Circuit holds."[2]
  • The outcome:In a 6-3 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Sixth Circuit, holding that probable cause for one charge in a criminal proceeding does not categorically bar a Fourth Amendment malicious-prosecution claim regarding another unsubstantiated charge.[1]


    • The case came on a writ of certiorari to the United States Court of Appeals for the Sixth Circuit. To review the lower court's opinion, click here.[3]

    Timeline

    The following timeline details key events in this case:

    Background

    Petitioner Jascha Chiaverini managed jewelry store Diamond and Gold Outlet in Napoleon, Ohio. He bought a men's ring and an earring from Brent Burns for $45.00. Burns alleged that he owned the jewelry. Later that day, David and Christina Hill each called the store seeking their stolen jewelry. According to Chiaverini's petition for a writ of certiorari, the Hills' descriptions of the ring varied and differed from the ring he had just purchased from Burns. He denied purchasing their stolen ring and advised them to file a police report. He called the police for assistance as well.[3][4][5]

    Police officers David Steward and Nicholas Evanoff responded to the jewelry store. Steward concluded that the jewelry had been stolen and belonged to the Hills. Evanoff confirmed the theory and instructed Chiaverini not to sell the jewelry at issue. Steward filed a report, the facts of which were later in dispute during the court proceedings; Chiaverini alleged in his certiorari petition to the U.S. Supreme Court hat the report detailed his cooperation.[4] According to the Sixth Circuit opinion:[3][4][5]

    “ Officer Steward authored the narrative report on this incident. And later, Steward added "additional details concerning the discussion[.]" One of the updates was a statement that Chiaverini allegedly made to Officer Evanoff. According to Steward, Chiaverini stated that "the reason he bought the ring and kept records regarding the purchase, was because he suspected that it was in fact stolen." In support of this, Officer Evanoff later said that Chiaverini "stated he believed . . . the ring to be stolen" and "[t]hat's why he filled out the buy card, because Brent Burns normally sold him fake jewelry." But Chiaverini denies saying this.[6] ”


    The police issued Chiaverini a hold letter with instructions on how to handle the Hill's jewelry as evidence of a crime. Chiaverini was confused by the letter's instructions—it ordered him to retain the items as proof of theft, and to return the jewelry to the Hills. He sought legal counsel and clarification from the police on how to proceed and chose to hold the jewelry. The police returned and directed Chiaverini to return the jewelry, but he kept the jewelry, claiming that it would be a crime to return it, based on his legal counsel's advice. Chiaverini also interacted with Police Chief Robert Weitzel regarding the letter, and their accounts differ as to what occurred. Chiaverini alleged he sought further clarification and received none, Weitzel alleged that Chiaverini said he would keep the jewelry and did not have to follow the letter's instructions. Later, Weitzel testified that Chiaverini "alluded to the fact that he didn't have a [precious-metal-dealers] license." To which Weitzel responded, "I think you have more problems than just this particular ring if you're operating without a license."[3] According to the Ohio Department of Commerce's website, Chiaverini's precious-metals-dealers license was inactive. Weitzel concluded that Chiaverini received stolen property without the right to hold it. With that, the police expanded their investigation into Chiaverini.[3][4][5]

    Chiaverini, meanwhile, alleged that when the police returned to his store, they suggested that Chiaverini would be viewed as another victim of Burns' crime if Chiaverini returned the jewelry to the Hills. Chiaverini alleged he was confused by what they meant and held onto the jewelry. As well, Chiaverini alleged that the police report had been altered:[4]

    “ 5. Altering the Police Report. On December 2, Evanoff and Steward met with a prosecutor to discuss next steps. R. 88-4, Page ID # 1117. That same day, Steward altered the November 16 police report that police had submitted regarding the Burns transaction. Petr. C.A. Br. 13-14. Steward changed the description of Mr. Chiaverini’s conversation with Evanoff that had taken place sixteen days prior. He inserted the following sentence: “Jascha [Chiaverini] advised Ptl. Evanoff that the reason he bought the ring and kept records regarding the purchase, was because he suspected that it was in fact stolen.” R. 89-13, Page ID# 1302.


    This new sentence was false. Mr. Chiaverini had never told Evanoff that he suspected the jewelry was stolen when he bought it from Burns.

    Although Steward altered the police report, he did not change the date of the report. ...[6]

    		”


    The police secured arrest and search warrants against Chiaverini and arrested him, charging him with (1) receiving stolen property; (2) Ohio Precious Metals Dealers Act ("OPMDA") licensure violations; and (3) money laundering. They seized items from his store related to the charges. The criminal charges against Chiaverini were later dismissed in state court for being untimely in presenting the case to the grand jury, and his seized belongings were returned.[3][4][5]

    Chiaverini filed complaints against the City of Napoleon, the officers, and officials related to the case, alleging, among other things, malicious prosecution. The United States District Court for the Northern District of Ohio granted the officers' motions for summary judgment based on qualified immunity and state-law immunity, holding that because probable cause supported Chiaverini's arrest and the related search warrants, Chiaverini's claims should be dismissed.[3][4][5]

    On appeal to the United States Court of Appeals for the 6th Circuit, a three-judge panel affirmed the Northern District of Ohio's grant of summary judgment and dismissal of Chiaverini's claims:[3]

    “ After Jascha Chiaverini bought stolen jewelry, he faced several demands to return the property. The rightful owners, a police letter, and several officers requested its return. But Chiaverini refused. He instead confronted the chief of police and alluded that he operated his business without a license. Following a police investigation, a municipal judge issued arrest and search warrants against Chiaverini for retaining stolen property, a licensing violation, and money laundering. And a preliminary hearing confirmed the probable cause underlying those charges. After those charges were dropped, Chiaverini filed a 42 U.S.C. § 1983 action, alleging malicious prosecution and false arrest. Because probable cause existed, the district court granted summary judgment on his claims. And we affirm for the same reason.[6] ”
    —Judge John Nalbandian


    On July 14, 2023, Chiaverini appealed to the U.S. Supreme Court, seeking review of the rules for bringing malicious prosecution claims under the Fourth Amendment. SCOTUS accepted the case to its merits docket on December 13, 2023.


    42 U.S. Code § 1983 - Civil action for deprivation of rights

    The legal statute at issue in the case is 42 U.S. Code § 1983 - Civil action for deprivation of rights. Section 1983 states:Cite error: Invalid <ref> tag; name cannot be a simple integer. Use a descriptive title

    “ Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.[6] ”
    —Cornell Law School Legal Information Institute, 42 U.S. Code § 1983 - Civil action for deprivation of rights

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether Fourth Amendment malicious prosecution claims are governed by the charge-specific rule, as the Second, Third, and Eleventh circuits hold, or by the "any-crime" rule, as the Sixth Circuit holds.[6] ”

    Oral argument

    Audio

    Audio of oral argument:[7]




    Transcript

    Transcript of oral argument:[8]


    Outcome

    In a 6-3 opinion, the court vacated and remanded the judgment of the United States Court of Appeals for the Sixth Circuit, holding that if an official has multiple charges against a defendant, and only one of those charges lacks probable cause, the valid charges do not exempt the official from a Fourth Amendment malicious-prosecution claim for the invalid charge. Probable cause for one charge in a criminal proceeding does not categorically bar a Fourth Amendment malicious-prosecution claim regarding another unsubstantiated charge. Justice Elena Kagan delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Justice Elena Kagan wrote:[1]

    “

    The question here is whether a Fourth Amendment malicious-prosecution claim may succeed when a baseless charge is accompanied by a valid charge. The Court of Appeals, as described above, answered that question with a categorical no: Even if the felony count lacked probable cause, the Sixth Circuit held, Chiaverini could not recover because the misdemeanor counts were adequately supported. See supra, at 3–4. But a funny thing happened on the way to this Court. The officers now agree with Chiaverini that there is no such flat bar. See Brief for Officers 24–27; Brief for Chiaverini 2–3. And the United States as amicus curiae also argues that the Sixth Circuit rule is wrong. See Brief for United States 10. We agree with them all. Consistent with both the Fourth Amendment and traditional common-law practice, courts should evaluate suits like Chiaverini’s charge by charge.[6]

    		”
    —Justice Elena Kagan

    Dissenting opinion

    Justice Clarence Thomas

    Justice Clarence Thomas filed a dissenting opinion, joined by Justice Samuel Alito.

    In his dissent, Justice Thomas wrote:[1]

    “

    Jascha Chiaverini sued several city officials for damages under 42 U. S. C. §1983. He alleged that they violated his Fourth Amendment rights by subjecting him to a malicious prosecution. I continue to adhere to my belief that a ‘malicious prosecution claim cannot be based on the Fourth Amendment.’ Manuel v. Joliet, 580 U. S. 357, 378 (2017) (ALITO, J., joined by THOMAS, J., dissenting). Accordingly, I would affirm the dismissal of Chiaverini’s claim.[6]

    		”
    —Justice Samuel Alito

    Justice Neil Gorsuch

    Justice Neil Gorsuch filed a dissenting opinion.

    In his dissent, Justice Gorsuch wrote:[1]

    “

    Section 1983 performs vital work by permitting individuals to vindicate their constitutional rights in federal court. But it does not authorize this Court to expound new rights of its own creation. As this Court has put it, §1983 does not turn the Constitution into a ‘‘‘font of tort law.’’’ Albright v. Oliver, 510 U. S. 266, 284 (1994) (Kennedy, J., concurring in judgment) (quoting Parratt v. Taylor, 451 U. S. 527, 544 (1981)).

    Despite that settled rule, the Court today doubles down on a new tort of its own recent invention—what it calls a ‘Fourth Amendment malicious-prosecution’ cause of action. Ante, at 1; see Thompson v. Clark, 596 U. S. 36, 43– 44 (2022). Respectfully, it is hard to know where this tort comes from. Stare for as long as you like at the Fourth Amendment and you won’t see anything about prosecutions, malicious or otherwise. Instead, the Amendment provides that ‘[t]he right of the people to be secure . . . against unreasonable searches and seizures, shall not be violated.’

    As its language suggests, the Fourth Amendment supplies nothing like a common-law claim for malicious prosecution. Ante, at 2 (THOMAS, J., dissenting); see Cordova v. Albuquerque, 816 F. 3d 645, 662–663 (CA10 2016) (Gorsuch, J., concurring in judgment). Just consider some of the differences. This Court has long held that the touchstone of the Fourth Amendment is objective reasonableness. But a common-law malicious-prosecution claim focuses on the defendant’s subjective intent. Ante, at 2 (opinion of THOMAS, J.). The Fourth Amendment addresses the permissibility of a seizure. But a common-law malicious-prosecution claim can (and usually does) proceed without one. Ante, at 2–3. A seizure in violation of the Fourth Amendment can (and often does) take place without the initiation of any judicial process. But the whole point of a maliciousprosecution claim is to contest the appropriateness of past judicial proceedings. Ante, at 2. For all these reasons, it’s ‘pretty hard to see how you might squeeze anything that looks quite like the common law tort of malicious prosecution into the Fourth Amendment.’ Cordova, 816 F. 3d, at 663 (opinion of Gorsuch, J.).[6]

    		”
    —Justice Neil Gorsuch

    Text of the opinion

    Read the full opinion here.

    October term 2023-2024

    See also: Supreme Court cases, October term 2023-2024

    The Supreme Court began hearing cases for the term on October 2, 2023. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 1.5 U.S. Supreme Court, "Chiaverini v. City of Napoleon, Ohio: CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT," June 20, 2024
    2. ↑ 2.0 2.1 U.S. Supreme Court, "23-50 CHIAVERINI V. NAPOLEON, OH, QUESTION PRESENTED" accessed December 20, 2023
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 U.S. Court of Appeals for the Sixth Circuit, Chiaverini v. City of Napoleon, decided January 11, 2023
    4. ↑ 4.0 4.1 4.2 4.3 4.4 4.5 4.6 U.S. Supreme Court, "Chiaverini v. City of Napoleon, Ohio: PETITION FOR A WRIT OF CERTIORARI," filed July 14, 2023
    5. ↑ 5.0 5.1 5.2 5.3 5.4 Oyez, "Chiaverini v. City of Napoleon, Ohio," accessed April 16, 2024
    6. ↑ 6.0 6.1 6.2 6.3 6.4 6.5 6.6 6.7 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued April 15, 2024
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued April 15, 2024
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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