Thompson v. Clark
Issues
Does the favorable termination element of a Section 1983 claim alleging unreasonable seizure require a plaintiff to show that the criminal proceedings at issue terminated in a way that affirmatively indicates the plaintiff’s innocence?
This case asks the Supreme Court to determine whether the “favorable termination” element of a Section 1983 claim alleging unreasonable seizure requires a petitioner to show that the criminal proceedings at issue terminated in a way that is consistent with his innocence. Petitioner Larry Thompson brought a Section 1983 claim against his arresting officers for violating his Fourth Amendment rights after his criminal charges were dismissed “in the interest of justice,” with no further explanation regarding Thompson’s innocence or guilt. Thompson claims that his criminal proceedings terminated favorably, but Respondent Paigel Clark—an arresting police officer— argues that Thompson failed to meet this requirement, asserting that charges must be dismissed in a way that affirmatively indicates innocence. This case has important implications for the future of Section 1983 claims, prosecutorial discretion, and police officer accountability.
Questions as Framed for the Court by the Parties
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,” as the U.S. Court of Appeals for the 11th Circuit decided in Laskar v. Hurd, or that the proceeding “ended in a manner that affirmatively indicates his innocence,” as the U.S. Court of Appeals for the 2nd Circuit decided in Lanning v. City of Glens Falls.
In January 2014, Petitioner Larry Thompson lived with his fiancé, their newborn child, and his fiancé’s sister, Camille Watson, in Brooklyn, New York. Thompson v. Clark at 182. One night, Watson noticed a rash on the newborn child and called 911 to report that Thompson was abusing his child. Id. When Emergency Medical Technicians (“EMT”) arrived, Thompson confronted them, telling them that no one in the apartment had called 911. Id.
Additional Resources
- Daniel Graziano, US Supreme Court takes up ‘favorable termination’ case, rejects Trump’s final election challenge, Jurist (Mar. 9, 2021).