Thompson v. Clark (U.S. Supreme Court)

Attorney(s): 

Can a police officer who frames an innocent person be held accountable in court? Before the MacArthur Justice Center won this landmark decision in Thompson v. Clark, the answer across most of the country was no: Once the innocent person got the false charges against them dismissed, the police officer who fabricated or falsified evidence against them was immune from a civil lawsuit. That was so no matter how devastating the false charges were to the innocent person’s life. We took that issue all the way to the U.S. Supreme Court and won. Following the Supreme Court’s decision, someone who is the victim of false or fabricated evidence by law enforcement can hold the government accountable for it.

In January 2014, Larry Thompson, a Black veteran of the Navy and U.S. postal worker, was at home with his fiancé and one-week-old daughter. As they were getting ready for bed, emergency medical technicians (EMTs) arrived at Mr. Thompson’s apartment building investigating a false report of child abuse. The EMTs went to Mr. Thompson’s apartment unit and were able to see his daughter safe in her mother’s arms. Upon asking the EMTs what they were investigating, Mr. Thompson told them, “I’m sorry, you got the wrong apartment” and then tried to help the EMTs brainstorm other apartments with children. The EMTs told Mr. Thompson they must have had the wrong unit and left his apartment.

Shortly thereafter, four NYPD officers arrived at Mr. Thompson’s building. After speaking with the EMTs, the officers went to Mr. Thompson’s unit and insisted on entering his home. Mr. Thompson asked to speak with the officers’ supervisor and, after they refused, asked to see a warrant. The officers then forcibly entered the apartment, violently tackling Mr. Thompson to the ground and handcuffing him. Although Mr. Thompson never resisted the officers, they pinned him face down on the floor, pressing into his head and back. The officers and EMTs then entered Mr. Thompson’s apartment and confirmed there had been no abuse.

In order to justify their force and the injuries they had caused to Mr. Thompson, an officer falsely reported that Mr. Thompson was the aggressor and violently resisted the officers. As a result of the false statements, Mr. Thompson was taken to jail and wrongfully charged with resisting arrest and obstructing governmental administration. After months of having to defend himself against those false charges, the District Attorney dismissed the charges against Mr. Thompson “in the interest of justice.”

Mr. Thompson then brought a civil-rights claim alleging that the police officer who fabricated the charges violated his rights under the Fourth Amendment to the U.S. Constitution. A federal court in New York ruled that Mr. Thompson could not sue the officer. According to the court, suing the officer required a “favorable termination” of Mr. Thompson’s criminal proceeding and dismissal of the charges against Mr. Thompson was not a favorable termination. The U.S. Court of Appeals for the Second Circuit affirmed.

We convinced the U.S. Supreme Court to hear Mr. Thompson’s case and MacArthur Justice Center attorney Amir Ali argued Mr. Thompson’s case before the Justices on October 12, 2021. On April 4, 2022, the Supreme Court issued a landmark ruling in Mr. Thompson’s favor. The Court explained that it “would make little sense” to preclude Mr. Thompson from proceeding with his civil suit. Rejecting the rule that applied across most of the country, the Supreme Court made clear that the victim of false charges “need only show that his prosecution ended without a conviction” in order to sue. And the Court held that Mr. Thompson “satisfied that requirement.”

CASE DEVELOPMENTS

  • U.S. Supreme Court rules in favor of Mr. Thompson — 
    April 4, 2022
  • U.S. Supreme Court hears oral argument — 
    October 12, 2021
  • U.S. Supreme Court grants review  — 
    March 8, 2021
  • MacArthur Justice Center files petition for certiorari on behalf of Mr. Thompson — 
    November 6, 2020

For media inquires please contact:

comms@macarthurjustice.org