Chiaverini v. City of Napoleon

In Napoleon, Ohio, jewelry store owner Jascha Chiaverini was charged with receiving stolen property and money laundering after Detective Nicholas Maro alleged he bought stolen gold items. The charges were later dismissed. Chiaverini sued the City of Napoleon and Maro under the Fourth Amendment for malicious prosecution, claiming the detective made false statements in his affidavit. The district court and Sixth Circuit ruled that because at least one charge was supported by probable cause, the entire malicious prosecution claim failed. The Supreme Court reversed, holding that a Fourth Amendment malicious prosecution claim may proceed if any individual charge lacked probable cause and caused a seizure, even when other charges were valid.

The Supreme Court reversed the Sixth Circuit and remanded, ruling that plaintiffs may pursue a Fourth Amendment malicious prosecution claim based on an individual charge that lacked probable cause, without showing that all charges were unsupported.

Whether a Fourth Amendment malicious prosecution claim requires every criminal charge to lack probable cause, or whether the claim can proceed based on a single charge lacking probable cause even if other charges had probable cause.

The decision clarifies that probable cause must be assessed charge-by-charge in Fourth Amendment malicious prosecution cases. It prevents police from shielding baseless charges behind one valid charge and strengthens civil rights protections for individuals subjected to wrongful arrests and prosecutions.