Lack of probable cause is an essential element of a Section 1983 Fourth Amendment malicious prosecution claim. What if the plaintiff was prosecuted on multiple criminal charges and there was probable cause for one charge but not another charge? In Chiaverini v. City of Napoleon, 144 S. Ct. 1745 (2024), the court held that probable cause on one charge does not preclude a Section 1983 malicious prosecution claim based on lack of probable cause on another charge. The court, however, left open an important issue of causation.