Beaman v. FreesmeyerAnnotate this Case
In 1993, ISU student Lockmiller was found dead in her Normal apartment. Police questioned Lockmiller’s then-boyfriend, Swaine, and former boyfriends, including Beaman. At a meeting including the McLean County prosecutors and several detectives, the prosecutors decided to charge Beaman. In discussing Lockmiller’s relationship with Murray with defense counsel, the prosecution did not disclose Murray’s drug use and incidents of domestic violence against another girlfriend, nor Murray’s incomplete polygraph examination. At trial, the state argued that all other possible suspects were excluded by alibis. Beaman was convicted of first-degree murder. Beaman sought postconviction relief, based on failure to disclose material information on Murray’s viability as a suspect. In 2008, the Illinois Supreme Court vacated Beaman’s conviction. The state dismissed the charges. In April 2013, the state certified his innocence. Beaman filed a 42 U.S.C. 1983 suit against the prosecutors and detectives with state law claims, including malicious prosecution, against the Town of Normal. The district court dismissed the claims. In 2014, Beaman filed a state court suit against the detectives and Normal, pleading the state law claims that the federal court had dismissed without prejudice. The circuit court granted defendants summary judgment, reasoning that Beaman could not satisfy the elements to establish malicious prosecution, noting testimony that the prosecutor rejected suggestions to investigate other avenues. The appellate court affirmed. The Illinois Supreme Court reversed. The appellate court erroneously focused its inquiry on whether the “officer[s] pressured or exerted influence on the prosecutor’s decision or made knowing misstatements upon which the prosecutor relied" and failed to consider whether the defendants proximately caused the commencement or continuance or played a significant role in Beaman’s prosecution.