Thompson v. Clark

Larry Thompson was arrested by NYPD Officer Pagiel Clark in 2014 after a dispute with his sister-in-law and charged with obstructing breathing and resisting arrest. He was detained for two days and later acquitted at trial. Thompson subsequently filed a federal civil rights lawsuit under 42 U.S.C. §1983, alleging a Fourth Amendment malicious prosecution claim against Officer Clark. The lower courts dismissed the suit, ruling that Thompson failed to show the criminal case terminated in a manner that affirmatively indicated his innocence. The Supreme Court reversed, holding that a plaintiff need only demonstrate that the criminal prosecution ended without a conviction, without separately proving innocence. The decision settled a circuit split over the favorable termination requirement.

In a 6-3 decision delivered by Chief Justice John Roberts, the Supreme Court held that to satisfy the favorable termination element of a malicious prosecution claim, a plaintiff need only show that the criminal prosecution ended without a conviction. The judgment of the Second Circuit was reversed.

Whether a plaintiff bringing a Fourth Amendment malicious prosecution claim under §1983 must prove that the criminal proceedings ended in a way that affirmatively indicates innocence, or merely that the prosecution concluded without a conviction.

The ruling lowered the evidentiary burden for bringing federal malicious prosecution claims, making it easier for individuals who were wrongfully charged but never formally exonerated to seek relief in federal court. It reinforced Fourth Amendment protections against baseless criminal proceedings and resolved a split among circuit courts, promoting greater uniformity in civil rights litigation.