Thomas v. Smith, et al, No. 11-2882 (8th Cir. 2012)
Annotate this CasePlaintiffs, wrongly convicted in 1989 for participating in the rape and murder of the victim, individually filed causes of action pursuant to 42 U.S.C. 1983 against defendants, contending that defendants violated their rights to due process by recklessly investigating the murder and by coercing plaintiffs to plead guilty. On appeal, plaintiffs challenged the district court's grant of defendants' motion for summary judgment based on qualified and absolute immunity. The court concluded that the district court erred by failing to grant all reasonable inferences to plaintiffs and that the evidence was sufficient to support plaintiffs' claims that their individual rights to fair criminal proceedings were violated as the result of a reckless investigation and defendants' manufacturing of false evidence. The district court did not err, however, in its determination that there was insufficient evidence to support plaintiffs' claims that their guilty pleas were unconstitutionally coerced. Additionally, the district court did not err in granting absolute immunity to the prosecutor. Accordingly, the court affirmed in part and reversed in part.
Court Description: Civil case - Civil rights. In Section 1983 action for wrongful conviction alleging reckless investigation, the manufacturing of false evidence and the coercion of guilty pleas, the district court erred in granting defendants' motion for summary judgment on plaintiffs' claims that their rights to a fair criminal proceeding were violated by the reckless investigation and manufactured evidence, and the summary judgment on those counts is reversed; however, the court did not err in determining that there was insufficient evidence to support plaintiffs' claim that their guilty pleas were unconstitutionally coerced; the district court did not err in concluding the county prosecutor was entitled to absolute immunity; claims against Gage County and the defendants in their official capacities are reinstated.
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