White v. Searcey, et al, No. 11-3291 (8th Cir. 2012)
Annotate this CasePlaintiff, wrongly convicted of murder and rape and imprisoned for these convictions, filed an action under 42 U.S.C. 1983 against defendants and various state entities, alleging that they violated his due process rights by conspiring to manufacture evidence and obtain false testimony against him. The court concluded that the facts viewed in the light most favorable to plaintiff gave rise to the reasonable inference that defendants acted in concert with the goal of securing plaintiff's convictions and thus, the district court did not err in denying defendants' request for summary judgment on the conspiracy claim. The court also concluded that a factfinder could reasonably infer that defendants' actions shocked the conscience and that the right to be free from a reckless investigation was clearly established during the 1989 investigation into this case. Further, the right to be free from a conviction purposefully obtained by false evidence and false testimony was also established.
Court Description: Civil case - Civil rights. For a related case, see the court's opinion in No. 11-2882, Winslow v. Smith, issued this date. The district court did not err in denying defendants' motion for summary judgment based on qualified immunity as there was sufficient evidence to show that defendants acted in concert to violate White's civil rights by manufacturing false evidence, and the district court did not err in concluding that the violations were so egregious that they shocked the conscience; the right to be free from the purposeful use of false evidence to secure a conviction was clearly established at the time of defendants' actions.
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