Burton v. St. Louis Board of Police, et al., No. 12-2524 (8th Cir. 2013)
Annotate this CaseAfter plaintiff served 24 years in prison for murder, a Missouri court found that plaintiff's trial had been fundamentally unfair and ordered his release. Plaintiff then filed suit against the St. Louis Board of Police Commissioners and others, alleging, inter alia, that defendants recklessly or intentionally manipulated evidence and conducted suggestive identification procedures. The court concluded that the district court did not err in granting summary judgment on plaintiff's claims that defendants manipulated the investigation or evidence against him or deprived him of a fair trial; plaintiff had not adduced evidence to show that the identification procedure in this case was impermissibly suggestive and the circumstances of the photo identification procedure did not create a very substantial likelihood of irreparable misidentification; the court found no evidence to support a reasonable inference that any of the defendants conspired to frame plaintiff or otherwise deprive him of his constitutional rights; and plaintiff's Monell claims against the Board failed where none of the individual defendants were liable on plaintiff's 42 U.S.C. 1983 claims. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - Civil rights. In action alleging defendants recklessly or intentionally manipulated evidence, conducted suggestive identification procedures and conspired to deprive plaintiff of a fair criminal trial, the district court did not err in granting defendants' motions for summary judgment; nor did the district court err in dismissing plaintiff's Monell claims against the Police Board since none of the individual defendants were liable on plaintiff's Section 1983 claims.
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