Helmig v. Fowler, No. 14-3422 (8th Cir. 2016)
Annotate this CaseIn 1996, Dale Helmig was convicted of first-degree murder of his mother. In 2011, the Missouri Court of Appeals vacated his conviction and gave the State 180 days to retry him. The State declined to retry Helmig. Helmig then filed suit against law enforcement officers and Osage County, Missouri under 42 U.S.C. 1983, alleging that they violated his constitutional right to due process by not disclosing certain materially favorable evidence, fabricating evidence, and conspiring to misuse evidence. The court found no intent or bad faith on behalf of the officers to disclose Brady evidence to the prosecutor or the defense; Sheriff Fowler’s lack of testimony at trial about his limited knowledge of the report at issue when he was never asked about whether the report was or was not substantiated both fails to support a Brady claim and is protected by absolute immunity; and no reasonable juror could infer the existence of a conspiracy to deprive Helmig of a fair trial. Accordingly, the court affirmed the district court's grant of summary judgment to defendants.
Court Description: Shepherd, Author, with Colloton and Gruender, Circuit Judges] Civil case - Civil rights. In action alleging defendants conspired to withhold and fabricate evidence to secure plaintiff's conviction for murder, the district court did not err in granting defendant Fowler's and Backues's motion for summary judgment; there is no evidence that Sheriff Fowler intentionally or in bad faith withheld exculpatory evidence in violation of Brady v. Maryland, and there was no evidence that the defendants conspired to deprive plaintiff of a fair criminal trial.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.