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Manuel v. City of Joliet: Governmental Liability for Post-Charging Imprisonment

(171 reviews)

Produced on September 14, 2017

$ 89 Criminal, Constitutional, Civil Rights, and Public Interest In Stock
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Course Information

Time 1h
Difficulty Beginner

Course Description

On March 21, 2017, the Supreme Court decided Manuel v. City of Joliet, which presented the question of “[w]hether an individual’s Fourth Amendment right to be free from unreasonable seizure continues beyond legal process so as to allow a malicious prosecution claim based upon the Fourth Amendment.” The case was supposed to clarify the Court’s fractured ruling of from more than twenty years ago in Albright v. Oliver, but instead, the Court left the question open and provided little guidance to lower courts, and to states and municipalities.

Tillman J. Breckenridge, a partner at Bailey & Glasser, LLP in Washington, D.C., and Lisa Soronen, the Executive Director of the State and Local Legal Center, both provided amicus briefs in the case. They will explore the background to Manuel, the Court’s ruling, and its impact on future government litigation. They will further discuss how the decision fits into broader due process jurisprudence, including the evolution of liability for municipalities and state and local officials for process-based errors. 

Learning Objectives:

  1. Understand the relationship between claims against government actors for malicious prosecution and the constitutional amendments relating to process
  2. Grasp the evolution of this area of law, and where it may be headed
  3. Know the background of Manuel, and the basis for the Supreme Court’s decision
  4. Discuss the broader issue of process-based claims against governmental defendants, and related issues on the rise in the courts

Credit Information

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Lisa Soronen

State and Local Legal Center

Lisa Soronen is the Executive Director of the State and Local Legal Center in Washington, D.C.. In her role at the State and Local Legal Center, Soronen files amicus curiae briefs to the U.S. Supreme Court on behalf of members of the Big Seven—National Governors Association, National Conference of State Legislatures, The Council of State Governments, National League of Cities, United States Conference of Mayors, National Association of Counties and International City/County Management Association—in cases affecting state and local government. She filed an amicus brief on behalf of SLLC in Manuel. Prior to joining the SLLC, Soronen worked for the National School Boards Association and the Wisconsin Association of School Boards, and clerked for the Wisconsin Court of Appeals. She earned a juris doctorate at the University of Wisconsin Law School.

Tillman Breckenridge

Bailey & Glasser LLP

Tillman Breckenridge is a Partner in Bailey & Glasser, LLP’s Washington, D.C. office. He is the Chair of DRI’s Appellate Advocacy Committee, and has represented individuals, companies, organizations, and foreign, state, and local governments before the United States Supreme Court, every U.S. Court of Appeals, and many state appellate courts. Additionally, Tillman is an Adjunct Professor of Law at the William & Mary School of Law, where he directs the Appellate and Supreme Court Clinic. He prepared and filed an amicus brief on behalf of DRI in Manuel. Tillman has been named to the Washington, DC Super Lawyers and Virginia’s Legal Elite lists for appellate practice, is rated AV-Preeminent by Martindale-Hubbell, and has been named one of the National Bar Association’s 40 Trailblazers Under 40.


Marty D.

Good interplay between speakers. Nice to have diverse presentations beyond Socratic method

John M.

Best course I have taken on Lawline yet!

Eric P.

Excellent presenters. Informative and interesting program.

Christopher G.

Excellent topic - done very well

R. Christopher R.

Great seminar by people with first-hand knowledge of the case

Joseph L.

Very enjoyable and engaging analysis by the speakers. Recommend.

Marc P.

Well done, unbiased presentation

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