Fields v. City of Chicago, No. 17-3079 (7th Cir. 2020)Annotate this Case
Fields filed claims under 42 U.S.C. 1983 and state law against Chicago, Chicago police officers, and former Cook County prosecutors. Fields alleged that the defendants violated his constitutional rights and state law by fabricating evidence and withholding exculpatory evidence in a criminal investigation that resulted in Fields’s conviction for a 1984 murder. A retrial resulted in an acquittal, 12 years after the original trial. The individual who had implicated Fields in the crimes eventually confessed to committing the murder. Fields sought a certificate of innocence, which was denied.
After a third trial, the jury found in favor of Fields against Detectives O’Callaghan and Murphy on one of his section 1983 claims, against Chicago on Fields’s Monell liability claim, and against O’Callaghan on a claim for intentional infliction of emotional distress, and found for the defendants on the remaining claims. The jury awarded Fields $22 million in compensatory damages and punitive damages of $30,000 against O’Callaghan and $10,000 against Murphy. The Seventh Circuit affirmed, rejecting the detectives’ challenges to evidentiary rulings concerning wiretaps, character evidence, evidence of Fields’s 1972 murder conviction, and evidence concerning prison incidents. The evidence allowed a jury to conclude that the city had failed to take the necessary steps to address an unconstitutional practice of using street files and that there was a “systemic underproduction of exculpatory materials to prosecutors and defense counsel.”