Dowell v. Lincoln County, Missouri, et al., No. 13-2317 (8th Cir. 2014)
Annotate this CasePlaintiff filed suit against the County and others under 42 U.S.C. 1983, after he was investigated and prosecuted for rape and murder. On appeal, plaintiff argued that the district court erred in granting defendants summary judgment. The court concluded that officers did not violate plaintiff's Fifth Amendment right against self-incrimination where plaintiff failed to introduce sufficient evidence to raise a question of material fact as to whether the officers' conduct overbore plaintiff's will; the district court did not err by granting defendants summary judgment on plaintiff's Sixth Amendment claim where plaintiff failed to allege a violation of the right to counsel as no statements made by him without counsel present were introduced at trial; and the district court did not err by granting summary judgment to defendants on plaintiff's Fourth Amendment claim where Detective Bartlett's second probable cause statement would still have established probable cause if the omitted facts at issue had been included. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil Case - civil rights. Following interrogation, arrest, and acquittal of murder charges and dismissal of rape charges, grant of summary judgment in favor of officers in civil rights action alleging Fourth, Fifth and Sixth Amendment violations is affirmed. Circumstances during pre-Miranda-warning van ride to station do not show statements made were anything but voluntary. Dowell failed to show atmosphere during interrogation post-Mirranda warnings were so intimidating or coercive so as to compel him to be untruthful. Because no statements made by Dowell without counsel were presented at trial, district court did not err in granting summary judgment on Sixth Amendment claim. Dowell's Fourth Amendment claim failed because even with the omitted facts in the probable cause statement, probable cause existed.
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