Dean v. Cnty. of Gage, No. 14-1747 (8th Cir. 2015)
Annotate this CaseIn 1989 White was convicted of rape and murder. The prosecution used testimony and confessions from White’s five co-defendants, all of whom pled guilty to related charges. After DNA testing in 2008, all convictions were pardoned or overturned. They sued Gage County and the officers involved in their case. On earlier appeals from separate summary judgments, the Eighth Circuit determined: “evidence is sufficient to support Plaintiffs’ claims that their rights to fair criminal proceedings were violated as the result of a reckless investigation and Defendants’ manufacturing of false evidence”; evidence was sufficient to support a conspiracy claim; evidence was not sufficient to support a coercion claim; members of the sheriff’s office were not protected by qualified immunity; and the county attorney was protected by absolute immunity. After trial of the consolidated claims, the court dismissed plaintiffs’ conspiracy claim and all claims against Gage County, but denied qualified immunity to the officers. The Eighth Circuit reversed as to the County and affirmed the denial of qualified immunity. Plaintiffs “produced proof of questionable procedures” and “hasty condemnation” by officers in charge of policy-making. There was ample evidence that the sheriff created policies, supervised other officers, specifically directed, endorsed, and encouraged their activities, and was a final policymaker for the County.
Court Description: Benton, Author, with Wollman and Smith, Circuit Judges] Civil case - Civil rights. Plaintiffs were exonerated by DNA evidence and brought this action against the County and the officers involved in their cases. For the court's prior opinion in the matter see Winslow v. Smith, 696 F.3d 716 (8th Cir. 2012). Since this court's prior opinion denied qualified immunity for the officers as a matter of law, the district court should not consider a Rule 50 motion on qualified immunity unless substantially different evidence was adduced at trial; here the trial evidence did not support the officers' entitlement to qualified immunity, and the district court properly denied the renewed Rule 50 motion for qualified immunity; the mistrial in this case created the need for an immediate appeal and Rule 54(b) certification was appropriate as the certified issues are self-contained and an appellate ruling will finally resolve the sufficiency of plaintiffs' conspiracy claims against the defendants; the district court erred in dismissing plaintiffs' conspiracy claims on the ground the claim was waived on remand; viewed in the light most favorable to plaintiffs, the evidence was sufficient to give rise to the reasonable inference that defendants acted in concert with the goal of securing plaintiffs' convictions, and the district court erred in dismissing the conspiracy claim; the district court erred in dismissing all claims against the County as plaintiffs produced evidence that defendant sheriff DeWitt was the final policy maker for the county; whether the policy decisions violated plaintiffs' constitutional rights is a question for the jury in the second trial.
The court issued a subsequent related opinion or order on December 7, 2015.
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