Bledsoe v. Board Cty Comm. Jefferson KS, et al., No. 20-3252 (10th Cir. 2022)Annotate this Case
Plaintiff-Appellee Floyd Bledsoe spent sixteen years in prison for the November 1999 murder of his fourteen-year-old sister-in-law Camille in Jefferson County, Kansas. In 2015, new DNA testing and a suicide note from Bledsoe’s brother Tom supported Bledsoe’s longstanding claim that Tom was the killer and Bledsoe was innocent. A state court subsequently vacated Bledsoe’s convictions and prosecutors dismissed all charges against him. In 2016, Bledsoe filed this 42 U.S.C. § 1983 action against ten named defendants, most of whom were Kansas law enforcement officers. Bledsoe alleged that Defendants conspired to fabricate evidence implicating him in the murder and intentionally suppressed evidence that would have proved his innocence, thereby causing him to be charged, tried, and convicted without even probable cause to believe he was guilty. At issue in this appeal was the district court’s denial of a motion to dismiss filed pursuant to Federal Rule of Civil Procedure 12(b)(6) by Defendant-Appellants, all of whom were law enforcement officers employed by the Jefferson County Sheriff’s office. In their motion, Appellants argued they were entitled to qualified immunity because Bledsoe: (1) failed to state claims adequately alleging that Appellants deprived Bledsoe of his constitutional rights; and/or (2) any constitutional violations Bledsoe did adequately allege against Appellants were not clearly established in 1999, when the events at issue occurred. The district court denied Appellants qualified immunity on most of Bledsoe’s claims. After review, the Tenth Circuit affirmed in part and reversed in part the district court's judgment. The Court concluded that the Supreme Court’s decision in Parratt v. Taylor, 451 U.S. 527 (1981) did not preclude Bledsoe’s substantive due process claims. Further, the Court found Bledsoe adequately alleged substantive due process and Fourth Amendment claims against each Appellant for evidence fabrication and for suppressing exculpatory evidence, a malicious prosecution claim, conspiracy claims, and a failure-to-intervene claim. Lastly, the Court concluded all the constitutional violations Bledsoe alleged except his failure-to-intervene claim were clearly established in 1999. The district court, therefore, correctly denied Appellants qualified immunity on all but the failure-to-intervene claim.