Hawkins v. Gage County, et al., No. 13-3107 (8th Cir. 2014)
Annotate this CasePlaintiff, falsely accused of rape and jailed for seventeen days, filed suit under 42 U.S.C. 1983 against the County and police officers. Plaintiff alleged that the officers failed to account for certain evidence defendant claimed was exculpatory, both in investigating the claim and in drafting an affidavit used to obtain an arrest warrant. The court concluded that the officers' decision to focus on other investigative leads rather than pursue tenuous, circumstantial, and potentially biased testimony from bar patrons neither shocks the conscience nor indicates recklessness; the officers' reaction to the investigator's suspicion of the photos of the victim demonstrated the even-handedness of their investigation where they soon called in a forensic nurse and then confronted the victim; and plaintiff's remaining allegations of reckless failures on the part of the officers was without merit. Further, plaintiff failed to show any omissions in the affidavit that demonstrated that the officers were reckless. Without a constitutional violation by the officers, there can be no liability for the county. Accordingly, the court affirmed the judgment of the district court, which found no genuine dispute of material fact as to whether the officers committed any constitutional violations.
Court Description: Civil case - Civil rights. In action alleging police violated plaintiff's due process rights by failing to investigate leads which would have proved his innocence of rape charges and by omitting material facts from an arrest warrant application, there was no evidence officers purposely ignored evidence of his innocence or acted under systematic pressure to implicate him in the face of contrary evidence; as a result neither the investigation nor his detention were reckless or conscience-shocking; none of the omissions from the arrest warrant application constituted a Franks violation and no Fourth Amendment violation was shown.
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