The following excerpt is from Salem v. City of N.Y., 19-3091 (2nd Cir. 2020):
Next, Salem alleges that he was unreasonably seized from the date of his arrest to the date his bail was paid. But this argument too is unavailing. Salem's pretrial detention was the result of unpaid bail lawfully ordered by the criminal court on one or more of his outstanding criminal cases. Furthermore, while pre-trial detention is a seizure, it is reasonable, as is the case here, if it is supported by probable cause. See Bailey v. United States, 568 U.S. 186, 192 (2013). Salem cannot sustain his claim of unreasonable seizure for his detention after his arraignment where he did not allege a lack of probable cause for his arrest or pretrial detention. Notably, Salem was later
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