Caldwell v. City and County of San Francisco, No. 16-15473 (9th Cir. 2018)
Annotate this CasePlaintiff filed suit against SFPD officials under 42 U.S.C. 1983, alleging that defendants fabricated evidence against him during a murder investigation. The district court granted defendants' motions for summary judgment. The Ninth Circuit held that because Caldwell rebutted any presumption of prosecutorial independence, he established a triable issue as to whether plaintiff fabricated evidence against him. Therefore, the panel reversed and remanded as to Crenshaw. The panel held that Gerrans and Crowly's investigation techniques were not so coercive that they rose to the level of fabricated evidence, and thus affirmed as to these two defendants.
Court Description: Civil Rights. The panel affirmed in part and reversed in part the district court’s summary judgment and remanded in an action brought pursuant to 42 U.S.C. § 1983 alleging that San Francisco Police Department officials fabricated evidence against plaintiff during his investigation for murder. Plaintiff spent nearly twenty years in prison as a result of his murder conviction. He brought a § 1983 action after a state court granted his petition for writ of habeas corpus and ordered his release. Plaintiff alleged that a police sergeant deliberately manufactured a “show-up” by exposing him to a witness with the purpose of manipulating that witness into misidentifying plaintiff as the murder suspect. He further alleged that the sergeant deliberately fabricated a statement by plaintiff that placed plaintiff at the site of the shooting. Finally, plaintiff alleged that his interaction with police inspectors during a photo lineup were so coercive that they rose to the level of deliberate fabrication of evidence. In reversing the district court’s grant of summary judgment in favor of the police sergeant, the panel held that drawing all reasonable inferences in favor of plaintiff, he established that the sergeant had a motive to retaliate against him. He further raised a genuine issue as to whether the sergeant arranged the show up, deliberately fabricated the statement and memorialized it in falsified notes. The panel CALDWELL V. CITY & CTY. OF SAN FRANCISCO 3 held that plaintiff rebutted any presumption of prosecutorial independence and established a triable issue as to whether the allegedly fabricated identification and falsified statements caused him harm. In affirming the district court’s summary judgment as to the police inspectors, the panel held that their conduct during a photo line-up was not so coercive that it rose to the level of fabricated evidence.
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