Bryson v. City of Oklahoma City
2010 U.S. App. LEXIS 24822
10th Cir.2010Background
- Plaintiff David Bryson was wrongfully convicted in 1983 based on forensic testimony by Joyce Gilchrist.
- Gilchrist testified semen and hair at the scene matched Bryson, leading to his incarceration for 17 years.
- Exculpatory DNA testing later vacated the conviction and charges were dismissed after more than 20 years.
- Later analysis showed Gilchrist should have excluded Bryson even without DNA; her lab results contradicted trial testimony.
- Bryson sued the City of Oklahoma City and Gilchrist under §1983; he obtained $16.5 million against Gilchrist; the City moved for summary judgment.
- Indemnification cross-claims arose: Gilchrist and the City settled for $23,364.29 without Bryson’s participation; Bryson sought indemnification from the City but was denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the City can be held liable under §1983 for alleged failure to train/supervise. | Bryson argues deliberate indifference to training/supervision. | City contends no deliberate indifference shown in 1983. | No deliberate indifference shown; no municipal liability. |
| Whether Bryson has standing to pursue indemnification under Oklahoma law. | Bryson is the real party in interest and should participate. | Lampkin controls; plaintiff not real party; indemnification paid to employee. | Bryson not real party; cannot pursue indemnification. |
| Whether ratification or custom claims support municipal liability. | Evidence shows ratification or a custom of falsifying data. | No final policymaker ratified; no widespread custom proven. | No liability under ratification or custom theories. |
| Whether evidence supports a claim of malicious prosecution attributable to the City. | City’s failure to discipline after 1986 caused continued confinement. | Causal link too attenuated between 1986 actions and 1983 injury. | Link too attenuated; no municipal liability for malicious prosecution. |
Key Cases Cited
- City of Canton v. Harris, 489 U.S. 378 (U.S. 1989) (deliberate indifference standard for failure to train/supervise)
- Brimmer-Hoelter v. Twin Peaks Charter Acad., 602 F.3d 1175 (10th Cir. 2010) (deliberate indifference factors; training/supervision)
- Praprotnik v. City of San Diego, 485 U.S. 112 (U.S. 1988) (ratification and final policymaker decisions)
- Hinton v. City of Elwood, 997 F.2d 774 (10th Cir. 1993) (elements of municipal liability; policy or custom required)
- Barney v. Pulsipher, 143 F.3d 1299 (10th Cir. 1998) (deliberate indifference under narrow circumstances)
- Lampkin v. Little, 85 F.App’x 167 (10th Cir. 2004) (unpublished; indemnification real party in interest; employee beneficiary)
- Lampkin v. Little, 286 F.3d 1206 (10th Cir. 2002) (indemnification aims to relieve employee of liability; plaintiff incidental beneficiary)
- Yang v. City of Chicago, 137 F.3d 522 (7th Cir. 1998) (different statute; not controlling for Oklahoma law)
- Skevofilax v. Quigley, 810 F.2d 378 (3d Cir. 1987) (indemnification context; limitations on recoveries)
- Fye v. Okla. Corp. Comm'n, 516 F.3d 1217 (10th Cir. 2008) (de novo review standards in appeals; evidence considerations)
- Adler v. Wal-Mart Stores, Inc., 144 F.3d 664 (10th Cir. 1998) (reviewing court’s framing of record on appeal)
- Padhiar v. State Farm Mut. Auto. Ins. Co., 479 F.3d 727 (10th Cir. 2007) (de novo standard for summary judgment)
- Breaux v. Am. Family Mut. Ins. Co., 554 F.3d 854 (10th Cir. 2009) (interpretation of indemnification statutes)