Briscoe v. County of St. Louis, Missouri, et al., No. 11-3034 (8th Cir. 2012)
Annotate this CasePlaintiff sued St. Louis County and three of its police officers - Lane Hollandsworth, Stephen Deen, Sr., and Jack Webb - under 42 U.S.C. 1983, alleging that they violated his constitutional rights by causing his wrongful conviction for rape and delaying his exoneration. After dismissing the County from the case, the district court granted summary judgment to the individual defendants, dismissing all claims with prejudice. The court affirmed, holding that, even assuming Hollandsworth caused some degree of suggestiveness in the photo lineup, it did not violate plaintiff's constitutional rights; there was no material issue of fact whether Hollandsworth knew that the December 4, 1982, incident was exculpatory evidence and tried to suppress the evidence; and therefore, the district court did not err in granting summary judgment to Hollandsworth. The court also held that Deen did not violate defendant's due process rights by conducting an impermissibly suggestive live lineup. Further, the court held that the district court did not err in granting summary judgment to Webb where there was no evidence in the record that Webb signed a false affidavit. Finally, the district court did not err in denying the motion for leave on the basis of futility and the district court did not abuse its discretion in denying plaintiff's motion to alter or amend its judgment.
Court Description: Civil case - Civil Rights. In action claiming defendants' actions led to plaintiff's wrongful conviction for rape, even assuming defendant Hollandsworth caused some undue suggestion in a lineup, his actions did not violate plaintiff's constitutional rights because the victim's identification showed sufficient indicia of reliability to be admitted at trial; there was no evidence to show Hollandsworth understood a prior incident was exculpatory and tried to suppress the information; while Hollandsworth's investigatory actions may have been negligent they did not rise to the level of an unconstitutional violation of plaintiff's liberty interests; claims regarding defendant Dee's actions at the lineup rejected; no error in denying plaintiff's motion to amend his complaint or his motion to alter or amend the judgment.
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