Sanchez v. Hartley, No. 14-1385 (10th Cir. 2016)
Annotate this CaseThis appeal grew out of an investigation into a 2009 burglary and sexual assault of an 8-year-old girl. Four detectives and an investigator participated in the investigation. In carrying out the investigation, the detectives and investigator interviewed Tyler Sanchez, an 18-year-old with substantial cognitive disabilities. After lengthy interviews, Sanchez confessed to the burglary but not the sexual assault. The confession led the district attorney to charge Sanchez with burglary and sexual assault. Based in part on this confession, multiple judges found probable cause, resulting in pretrial detention. Sanchez alleged that his confession was false, explaining that he confessed only because his disabilities prevented him from understanding what was happening during the interviews. A subsequent medical examination supported Sanchez’s explanation, and the district attorney dropped the charges in April 2012. Sanchez then sued the detectives and the investigator, alleging that they had used a confession to obtain legal process even though they knew the confession was untrue. The defendants moved to dismiss based in part on qualified immunity and expiration of the limitations period. The district court rejected both grounds, and the defendants brought this interlocutory appeal. The Tenth Circuit affirmed the district court’s denial of the defendants’ motion to dismiss on the basis of qualified immunity; and it dismissed the defendants’ appeal of the district court’s ruling on the statute of limitations, holding that the Court lacked jurisdiction on this part of the appeal.
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