Burton v. St. Louis Board of Police Commissioners, 731 F.3d 784

Darryl Burton was convicted in 1985 for the murder of Donald Ball and sentenced to 75 years; new evidence later cast doubt on the trial, including perjury by an eyewitness and questions about another witness's ability to see the shooter.
Burton’s post-conviction efforts yielded a state habeas release after 24 years, recognizing fundamental unfairness in the trial.
Burton sued the St. Louis Board of Police Commissioners and several officers under 42 U.S.C. § 1983, alleging manipulation of evidence and suggestive identifications, plus state-law claims.
The district court granted summary judgment on the § 1983 claims after applying qualified-immunity analysis and dismissed the state-law claims.
On appeal, Burton challenges the district court’s handling of evidence manipulation, identification procedures, and conspiracy claims, arguing defendants violated clearly established rights.
The Eighth Circuit affirms, holding no genuine issue of material fact supports Burton’s § 1983 claims against the individual defendants, and Monell claims against the Board fail because underlying claims lack viability.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants violated Burton’s rights by manipulating evidence	Burton asserts defendants withheld exculpatory statements and manipulated witnesses.	Burton cannot show bad faith or that withheld material evidence denied a fair trial.	No genuine issue of material fact; no §1983 violation established.
Whether identification procedures were impermissibly suggestive	Walker and Simmons identifications were the product of impermissibly suggestive arrays.	Arrays were not impermissibly suggestive and reliability under totality of circumstances supports identification.	Identification procedures did not create a substantial likelihood of misidentification.
Whether Burton proved a conspiracy to deprive rights	Defendants conspired to frame Burton based on investigation information.	No meeting of the minds or overt act showing conspiracy.	Insufficient evidence of a conspiracy.
Whether Monell liability attaches to the Board	Board policies caused constitutional violations by officers.	No underlying §1983 violation by individual defendants; Monell fails.	Monell claim dismissed as underlying §1983 claims fail.

Briscoe v. County of St. Louis, Mo., 690 F.3d 1004 (8th Cir. 2012) (due-process standards for egregious investigations; conscience-shocking conduct)
King v. United States, 148 F.3d 968, 148 F.3d 968 (8th Cir. 1998) (reliability in identifications; substantial likelihood of misidentification factors)
Manson v. Brathwaite, 432 U.S. 98 (U.S. 1977) (reliability of eyewitness identifications; totality of circumstances)
Patterson v. New York, 432 U.S. 197 (U.S. 1977) (due-process limitations on efforts to eliminate errors in prosecution)
Baker v. McCollan, 443 U.S. 137 (U.S. 1979) (constitutional guarantees do not require arrest to reveal every possible error)
White v. McKinley, 519 F.3d 806 (8th Cir. 2008) (qualified-immunity burden and predicate facts at summary judgment)