Laskar v. Hurd

Dismissal of a prosecution as untimely satisfies the favorable termination element of malicious prosecution claim under Fourth Amendment: “After considering both the common law and Fourth Amendment, we hold that the favorable-termination element of malicious prosecution is not limited to terminations that affirmatively support the plaintiff’s innocence. Instead, the favorable-termination element requires only that the criminal proceedings against the plaintiff formally end in a manner not inconsistent with his innocence on at least one charge that authorized his confinement. A formal end to criminal proceedings will satisfy this standard unless it precludes any finding that the plaintiff was innocent of the charges that justified his seizure, which occurs only when the prosecution ends in the plaintiff’s conviction on or admission of guilt to each charge that justified his seizure.” Court also holds that initiation of criminal proceedings without probable cause satisfies “malice” element for malicious prosecution.