Jackson v. Cleveland, No. 17-3840 (6th Cir. 2019)Annotate this Case
n 1975, Jackson, Ajamu, and Bridgeman were convicted of murder, based largely on the purported eyewitness testimony of Vernon, who then was 13 years old. In 2014, Vernon recanted, disclosing that police officers had coerced him into testifying falsely. Vernon’s recantation led to the overturning of their convictions. The exonerated men filed suit under 42 U.S.C. 1983, along with state law claims for indemnification against Cleveland. The district court granted the defendants judgment on the pleadings. The Sixth Circuit affirmed summary judgment as to the section 1983 claims based on conspiracy, but reversed judgment on the pleadings as to the indemnification claims; denial of motions to amend the complaints to substitute the administrator of the estates of the deceased officers as a party in their place; summary judgment as to section 1983 claims arising from violations of Brady v. Maryland, fabrication of evidence, and malicious prosecution; and summary judgment as to “Monell” claims against Cleveland. The court noted evidence that officers may have been unaware of their “Brady” obligations, that Brady violations were common, and that officers intimidated Vernon.
The court issued a subsequent related opinion or order on May 20, 2019.