Thompson v. Clark
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Thompson v. Clark and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Thompson v. Clark.
In Thompson v. Clark, the Supreme Court addressed the requirement for a favorable termination in a Fourth Amendment claim under § 1983 for malicious prosecution. The Court determined that a plaintiff need not show an affirmative indication of innocence, only that the prosecution ended without a conviction. This decision resolves a split among the Courts of Appeals regarding the application of this requirement.
Holding
The single most important “bottom line” of what the Court decided in Thompson v. Clark.
The Court held that to demonstrate a favorable termination for a Fourth Amendment claim under § 1983 for malicious prosecution, a plaintiff need only show that the prosecution ended without a conviction.
Constitutional Concepts
These are the Constitution-related themes that appear in Thompson v. Clark. Click a concept to see other cases that involve the same idea.
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Why Search and Seizure is relevant to Thompson v. Clark
The case involves a Fourth Amendment claim under § 1983 for malicious prosecution, which directly relates to unreasonable searches and seizures.
Syllabus excerpt (verbatim)To maintain that Fourth Amendment claim under § 1983, a plaintiff such as Thompson must demonstrate, among other things, that he obtained a favorable termination of the underlying criminal prosecution.
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Why Procedural Due Process is relevant to Thompson v. Clark
The case discusses the requirement for a favorable termination of a criminal prosecution, which involves procedural due process considerations.
Syllabus excerpt (verbatim)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.
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Why Remedies and Relief is relevant to Thompson v. Clark
The case addresses the requirements for obtaining relief under § 1983 for malicious prosecution, which involves the scope of remedies available.
Syllabus excerpt (verbatim)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.
Key Quotes
Short excerpts from the syllabus in Thompson v. Clark that support the summary and concepts above.
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.
Doing so is consistent with 'the values and purposes' of the Fourth Amendment.