Montoya v. Vigil, No. 17-1106 (10th Cir. 2018)Annotate this Case
A jury convicted fourteen-year-old Lawrence Montoya for the New Year’s Day murder of a teacher from his school. After serving over thirteen years in prison, Montoya brought post-conviction claims for ineffective assistance of counsel and actual innocence. He sued several detectives involved in the investigation and trial, claiming they were responsible for his wrongful conviction pursuant to 42 U.S.C. 1983. Specifically, Montoya claimed the Detectives instigated a malicious prosecution against him, coerced his confession in violation of the Fifth Amendment, and subjected him to false arrest. The Detectives appealed when the district court held qualified immunity and absolute testimonial immunity did not shield the Detectives from liability and denied their motion to dismiss. After review, the Tenth Circuit held qualified immunity indeed shielded the Detectives from liability for Montoya’s malicious prosecution claim; both qualified immunity and absolute testimonial immunity barred Montoya’s Fifth Amendment claim. As for Montoya’s false arrest claim, the Court determined it lacked jurisdiction to consider whether or not qualified immunity applied.