Facts of the Case
“Upon learning that Illinois authorities had issued an arrest warrant charging him with the sale of a substance which looked like an illegal drug, petitioner Albright surrendered to respondent Oliver, a policeman, and was released after posting bond. At a preliminary hearing, Oliver testified that Albright sold the look-alike substance to a third party, and the court found probable cause to bind Albright over for trial. However, the court later dismissed the action on the ground that the charge did not state an offense under state law. Albright then filed this suit under 42 U.S.C. § 1983, alleging that Oliver deprived him of substantive due process under the Fourteenth Amendment – his “liberty interest” – to be free from criminal prosecution except upon probable cause. The District Court dismissed on the ground that the complaint did not state a claim under § 1983. The Court of Appeals affirmed, holding that prosecution without probable cause was a constitutional tort actionable under § 1983 only if accompanied by incarceration, loss of employment, or some other “palpable consequence.” Albright sought further review in the United States Supreme Court.”
Does the Equal Protection Clause of the Fourteenth Amendment require that districting take into account the number of people eligible to vote, rather than the total population?
No. The Court ruled that Section 1983 relief for prosecution without probable cause is only valid if the prosecuted party claims Fourth Amendment (pretrial rights) violations. In a 7-2 decision authored by Chief Justice William Rehnquist, the Courtt reaffirmed its commitment not to extend substantive due process indefinitely and held that substantive due process does not guarantee non-interference by criminal investigations.
Citation: 510 US 266 (1994)
Argued: Oct 12, 1993
Decided: Jan 24, 1994
Case Brief: 1994