Thompson v. Clark

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Supreme Court of the United States
Thompson v. Clark
Term: 2021
Important Dates
Argued: October 12, 2021
Decided: April 4, 2022
Outcome
Reversed and remanded
Vote
6-3
Majority
Brett Kavanaugh • Chief Justice John G. Roberts • Stephen Breyer • Sonia Sotomayor • Elena Kagan • Amy Coney Barrett
Dissenting
Samuel Alito • Clarence Thomas • Neil Gorsuch

Thompson v. Clark is a case that was decided by the Supreme Court of the United States on April 4, 2022, during the court's October 2021-2022 term. The case was argued before the court on October 12, 2021.

The court reversed and remanded the decision of the United States Court of Appeals for the 2nd Circuit in a 6-3 ruling. The court held that it was sufficient for a plaintiff suing for unconstitutional conviction or imprisonment under the favorable termination rule to show that the prosecution ended without a conviction. Justice Brett Kavanaugh delivered the majority opinion. He wrote, "[W]e hold that a Fourth Amendment claim under §1983 for malicious prosecution does not require the plaintiff to show that the criminal prosecution ended with some affirmative indication of innocence. A plaintiff need only show that the criminal prosecution ended without a conviction." Justice Samuel Alito dissented, joined by Justices Clarence Thomas and Neil Gorsuch.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: Plaintiff Larry Thompson was charged with obstructing government administration and resisting arrest related to a warrantless search conducted by police in Thompson’s home. Thompson spent two days in police custody before being released on his own recognizance. The prosecutor ultimately dropped the criminal charges. Thompson subsequently filed a civil suit against the police who arrested him for deprivation of his civil rights pursuant to 42 U.S.C. § 1983. The district court found for the defendants, holding that it was Thompson's burden to show exigent circumstances were lacking during a warrantless search under the Fourth Amendment and that the plaintiff’s criminal case did not end in a favorable termination for purposes of a suit under 42 U.S.C. § 1983.[2] On appeal, the United States Court of Appeals for the 2nd Circuit affirmed.[3] Click here to learn more about the case's background.
  • The issue: The case concerned the U.S. Supreme Court’s favorable termination rule for plaintiffs suing for unconstitutional conviction or imprisonment pursuant to 42 U.S.C. § 1983 and burden of proof requirements in cases of unlawful warrantless entry under the Fourth Amendment.
  • The questions presented:
    "1. Whether the rule that a plaintiff must await favorable termination before bringing a Section 1983 action alleging unreasonable seizure pursuant to legal process requires the plaintiff to show that the criminal proceeding against him has 'formally ended in a manner not inconsistent with his innocence,' Laskar v. Hurd, 972 F.3d 1278, 1293 (11th Cir. 2020), or that the proceeding 'ended in a manner that affirmatively indicates his innocence,' Lanning v. City of Glens Falls, 908 F.3d 19, 22 (2d Cir. 2018); see also Laskar, 972 F.3d at 1293 (acknowledging 7-1 circuit conflict).


    "2. Where a Section 1983 plaintiff brings a Fourth Amendment claim for unlawful warrantless entry of his home and the government pursues a justification of exigent circumstances, does the government have the burden to prove exigency existed (as the Third, Sixth, Ninth and Tenth Circuits have held), or does the plaintiff have to prove its non-existence (as the Second, Seventh and Eighth Circuits have held)."[4]

  • The outcome: The court reversed and remanded the decision of the United States Court of Appeals for the 2nd Circuit in a 6-3 ruling. The court held that it was sufficient for a plaintiff suing for unconstitutional conviction or imprisonment under the favorable termination rule to show that the prosecution ended without a conviction.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 2nd Circuit. To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    • April 4, 2022: The U.S. Supreme Court reversed and remanded the 2nd Circuit's decision in a 6-3 ruling.
    • October 12, 2021: The U.S. Supreme Court heard oral argument. The case was originally scheduled for arguments on November 1, 2021.
    • March 8, 2021: The U.S. Supreme Court agreed to hear the case.
    • November 6, 2020: Plaintiff Larry Thompson appealed to the U.S. Supreme Court.
    • February 24, 2020: The 2nd Circuit affirmed the United States District Court for the Eastern District of New York's ruling in favor of defendants.

    Background

    Plaintiff Larry Thompson was at home with his wife and baby when police knocked on his door and requested entry. The police reported receiving a 911 call alleging child abuse and said that they and the EMTs needed to enter the apartment to inspect the baby. The police did not have a warrant, and Thompson refused them entry. The police entered the apartment over Thompson's objections, testifying later in court that they believed exigent circumstances justified the warrantless entry. The baby was taken to the hospital and examined but doctors found no evidence of abuse. Police determined the 911 caller was Thompson's sister-in-law, who was temporarily staying with Thompson's family and had a history of mental illness.[2]

    Thompson was pushed to the ground and handcuffed by police when they entered his apartment. After being transported to the hospital for injuries he received during the altercation, Thompson was taken to the police station and charged with obstructing government administration and resisting arrest. He was held in police custody for two days before being released on his own recognizance. The district attorney's office ultimately dismissed the charges against him "in the interests of justice," without citing any specific reason for the dismissal.[2]

    Thompson subsequently brought a civil suit for deprivation of his rights pursuant to 42 U.S.C. § 1983 against the police officers who arrested him, arguing they violated his Fourth Amendment protections against unlawful search and seizure when they forced entry into his apartment without a warrant, thereby making his arrest and detention unlawful. The United States District Court for the Eastern District of New York examined two issues in the case: 1) which party in § 1983 action has the burden to prove or disprove the existence of exigent circumstances in a case for unlawful warrantless entry under the Fourth Amendment and 2) whether a dismissal of charges equates to a favorable termination for purposes of bringing suit under 42 U.S.C. § 1983.[2]

    With regard to proving exigent circumstances for a § 1983 suit, the district court noted a circuit split on the issue, but stated it was bound by the Second Circuit's precedent set out in Ruggiero v. Krzeminski that places the burden on the plaintiff in the suit. The court held that Thompson, as the plaintiff in this case, did not meet that burden and found for the defendants.[2]

    The favorable termination rule was set out by the U.S. Supreme Court in the 1994 case Heck v. Humphrey to guard against a § 1983 plaintiff's civil claims potentially undermining the validity of the plaintiff's criminal conviction.[5] The Supreme Court held that the § 1983 plaintiff's criminal proceeding must end in a favorable termination to the plaintiff in order for a suit to proceed, but circuit courts are split on how a favorable termination is defined. Some circuits hold that a judgment must affirmatively indicate a plaintiff's innocence—a higher standard—while others hold that the judgment simply must not be inconsistent with the plaintiff's innocence. The Second Circuit took the position in Lanning v. City of Glens Falls that a judgment must affirmatively indicate the plaintiff's innocence, and a dismissal of charges alone does not meet that burden. Accordingly, the district court found that Thompson did not meet the burden of the favorable termination rule required of § 1983 plaintiffs.[2]

    On appeal, the United States Court of Appeals for the 2nd Circuit affirmed the district court's ruling.[3]

    Questions presented

    The petitioner presented the following questions to the court:[4]

    Questions presented:
    “ 1. Whether the rule that a plaintiff must await favorable termination before bringing a Section 1983 action alleging unreasonable seizure pursuant to legal process requires the plaintiff to show that the criminal proceeding against him has 'formally ended in a manner not inconsistent with his innocence,' Laskar v. Hurd, 972 F.3d 1278, 1293 (11th Cir. 2020), or that the proceeding 'ended in a manner that affirmatively indicates his innocence,' Lanning v. City of Glens Falls, 908 F.3d 19, 22 (2d Cir. 2018); see also Laskar, 972 F.3d at 1293 (acknowledging 7-1 circuit conflict).


    2. Where a Section 1983 plaintiff brings a Fourth Amendment claim for unlawful warrantless entry of his home and the government pursues a justification of exigent circumstances, does the government have the burden to prove exigency existed (as the Third, Sixth, Ninth and Tenth Circuits have held), or does the plaintiff have to prove its non-existence (as the Second, Seventh and Eighth Circuits have held).[6]

    		”

    Oral argument

    The U.S. Supreme Court heard oral argument on October 12, 2021. The case was originally scheduled for arguments on November 1, 2021.

    Amir H. Ali, Esq., Washington, D.C., argued on behalf of the petitioner. John D. Moore, Esq., New York, New York, argued on behalf of the respondents.[7]

    Audio

    Audio of oral argument:[8]



    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 6-3 opinion, the court reversed and remanded the decision of the United States Court of Appeals for the 2nd Circuit. The court held that a plaintiff suing for unconstitutional conviction or imprisonment under the favorable termination rule was not required to provide an affirmative indication of innocence. Instead, the plaintiff only needed to show that the prosecution ended without a conviction. Justice Kavanaugh delivered the opinion of the court. Justice Alito filed a dissenting opinion, joined by Justices Thomas and Gorsuch.[1]

    Opinion

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

    “ To demonstrate a favorable termination of a criminal prosecution for purposes of the Fourth Amendment claim under §1983 for malicious prosecution, a plaintiff need not show that the criminal prosecution ended with some affirmative indication of innocence. A plaintiff need only show that his prosecution ended without a conviction. Thompson has satisfied that requirement here. ... Questions concerning whether a criminal defendant was wrongly charged, or whether an individual may seek redress for a wrongful prosecution, cannot reasonably depend on whether the prosecutor or court happened to explain why charges were dismissed. And requiring a plaintiff to show that his prosecution ended with an affirmative indication of innocence is not necessary to protect officers from unwarranted civil suits, as officers are still protected by the requirement that the plaintiff show the absence of probable cause and by qualified immunity.[6] ”
    —Justice Brett Kavanaugh

    Dissenting opinion

    Justice Alito filed a dissenting opinion, joined by Justices Thomas and Gorsuch.

    In his dissent, Justice Alito wrote:[1]

    “

    What the Court has done is to recognize a novel hybrid claim of uncertain scope that has no basis in the Constitution and is almost certain to lead to confusion. The Court asserts that malicious prosecution is the common-law tort that is most analogous to petitioner’s Fourth Amendment claim, ante, at 5, but in fact the Fourth Amendment and malicious prosecution have almost nothing in common. ... The Court's recognition of a Fourth Amendment malicious-prosecution claim has no basis in our precedents. ... Instead of creating a new hybrid claim, we should simply hold that a malicious-prosecution claim may not be brought under the Fourth Amendment. [6]

    		”
    —Justice Samuel Alito

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. 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]

    The court agreed to hear 68 cases during its 2021-2022 term.[10] Four cases were dismissed and one case was removed from the argument calendar.[11]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 Supreme Court of the United States, Thompson v. Clark - "Opinion," April 4, 2022
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 United States District Court for the Eastern District of New York, "Thompson v. Clark," decided March 12, 2019
    3. ↑ 3.0 3.1 United States Court of Appeals for the 2nd Circuit, "Thompson v. Clark," decided February 24, 2020
    4. ↑ 4.0 4.1 U.S. Supreme Court, "No. 20-659: Questions Presented," accessed March 8, 2021
    5. ↑ SCOTUSblog, "Thompson v. Clark," decided March 12, 2019
    6. ↑ 6.0 6.1 6.2 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ 7.0 7.1 U.S. Supreme Court, "Thompson v. Clark - Argument transcript," October 12, 2021
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed October 12, 2021
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    10. ↑ Consolidated cases are counted as one case for purposes of this number.
    11. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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