Judge Cindy Chung, nominated by President Biden to the Third Circuit court of appeals, wrote a 2-1 ruling that gave a man the chance to prove at trial unlawful search, false arrest, and malicious prosecution claims against police who invaded his home. The July 2024 decision was in Saintil v Borough of Carteret.
What happened in this case?
Shortly after arriving at his New Jersey apartment from a hard day’s work as a painter, Ronald Saintil was confronted by more than a dozen police who broke down his door and started questioning him. According to the civil rights complaint he later filed, the police included a detective from Carteret, some 45 minutes away, where a killing had occurred that was under investigation. Saintil tried to explain that he had never been to Carteret and had been in Pennsylvania on a job over the last three days.
The police obtained a search warrant, searched the house, and continued to question Saintil. They seized his laptop, cellphone, and car. He was arrested not for a murder charge but for “hindering” his own apprehension. He was detained in jail for ten days and then released. The “hindering” charge was dropped and no others were filed. While he was in jail, however, Saintil was evicted from his apartment, as he later explained, “due to the police investigation and the physical damage” caused by the police.
Saintil then filed a federal lawsuit, contending that the police had violated his civil rights. After some discovery, however, the district court granted summary judgment in favor of the police and against Saintil on all counts. He appealed to the Third Circuit.
How Did Judge Chung and the Third Circuit Rule and Why Is it Important?
Judge Chung wrote a 2-1 decision that reversed the ruling against Saintil as to his unlawful search, false arrest, and malicious prosecution claims, authorizing these charges to go to trial. On all of them, the court ruled that there were material facts in dispute that should be resolved by a jury.
Among other conclusions, the court determined that a “reasonable jury” could find that police “acted knowingly or with a reckless disregard for the truth” in providing information to justify their search warrant and that “there was a lack of probable cause” for the arrest and prosecution of Saintil. The answer to these questions, Chung continued, will “largely turn on credibility and the resolution of factual disputes, matters that should be determined by a jury.”
Judge Chung’s decision is obviously important to Ronald Saintil and his quest for justice against police for their allegedly improper behavior. The ruling also provides important analysis of claims of police misconduct that should prove useful in other cases, particularly in the Third Circuit, which includes Pennsylvania, New Jersey, and Delaware. The decision also serves as a reminder of the importance of promptly confirming fair-minded judges to our federal courts.