Riverside County v. McLaughlin

PETITIONER: Riverside County
RESPONDENT: McLaughlin
LOCATION: County of Riverside: District Attorney

DOCKET NO.: 89-1817
DECIDED BY: Rehnquist Court (1990-1991)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 500 US 44 (1991)
ARGUED: Jan 07, 1991
DECIDED: May 13, 1991

ADVOCATES:
Dan Stormer - Argued the cause for the respondents
Timothy T. Coates - Argued the cause for the petitioners

Facts of the case

McLaughlin was arrested without a warrant and argued that Riverside did not act promptly (within 48 hours) on judicial probable cause determinations and arraignment procedures in his case and others.

Question

Did Riverside violate the Court's holding in Gerstein v. Pugh (420 U.S. 103), which required prompt probable cause determinations?

Media for Riverside County v. McLaughlin

Audio Transcription for Oral Argument - January 07, 1991 in Riverside County v. McLaughlin

Audio Transcription for Opinion Announcement - May 13, 1991 in Riverside County v. McLaughlin

William H. Rehnquist:

The opinion of the Court in No. 89-1817, County of Riverside versus McLaughlin will be announced by Justice O'Connor.

Sandra Day O'Connor:

This case follows from an opinion of the Court handed down in the case of Gerstein versus Pugh where this Court held that the Fourth Amendment requires a prompt judicial determination of probable cause following a warrantless arrest.

The respondent, Mr. McLaughlin, brought this class action suit under Section 1983 against the County of Riverside in California.

The plaintiff's claim that County's policy governing probable cause determinations for persons arrested without a warrant violates the holding in the Gerstein case.

Currently, Riverside County combines probable cause determinations with its arraignment procedures, and it offers the combined proceedings within 48 hours of arrest exclusive of weekends and holidays.

Under this policy, persons arrested without a warrant could spend up to five or six days before receiving a probable cause hearing.

The District Court issued a preliminary injunction requiring that all persons arrested without a warrant be given a probable cause hearing within 36 hours of arrest.

The Ninth Circuit Court of Appeals affirmed holding that the County's policy was inconsistent with our holding in the Gerstein case which the Ninth Circuit Court of Appeals read to require probable cause determinations immediately on completion of the administrative steps incident to arrest.

In the opinion filed today, we hold that Riverside County is entitled to combined probable cause determinations with its arraignment proceedings, but that it must offer those combined proceedings within 48 hours or less following a warrantless arrest.

Weekends and holidays may not be excluded from this time limit.

Combined proceedings offered within 48 hours will, as a general matter, immunize jurisdictions from class action suits challenging a systemwide policy.

The 48-hour period does not provide jurisdictions with absolute immunity, however.

A jurisdiction may still be subject to an individual lawsuit if the plaintiff can prove that his or her probable cause determination was delayed unreasonably.

The judgment of the Court of Appeals is vacated and the case is remanded for further proceedings consistent with this opinion.

Justice Marshall has filed a dissenting opinion in which Justices Blackmun and Stevens have joined; Justice Scalia has filed a dissenting opinion.