Dean v. Searcey, No. 16-4059 (8th Cir. 2018)Annotate this Case
After plaintiffs were exonerated for the murder of Helen Wilson in 2008, they filed a 42 U.S.C. 1983 action, alleging that their arrests and imprisonment were the result of a reckless investigation and manufactured false evidence, as well as parallel conspiracy claims under 42 U.S.C. 1985. Plaintiffs were awarded approximately $28.1 million in damages. The Eighth Circuit held that it would not review or reverse its prior rulings as to whether Gage County could be held liable; the evidence was sufficient to support the jury's verdict finding Gage County liable; the facts developed at trial continued to support the district court's conclusion that the sheriff's deputies were not entitled to qualified immunity; the deputies conducted a reckless investigation and fabricated evidence; limited references to plaintiffs' innocence did not warrant a new trial in light of the curative actions and overwhelming evidence; and there was no error in the reckless investigation jury instruction.