Byron Halsey v. Frank Pfeiffer
2014 U.S. App. LEXIS 7696
| 3rd Cir. | 2014Background
- In 1985, Tyrone and Tina Urquhart were murdered; Clifton Hall, a neighbor with a prior sexual-history, was a prime suspect but Halsey was targeted instead.
- Halsey, a 24-year-old with limited education, was interrogated for about 30 hours, deprived of counsel at times, and signed a written confession after coercive interrogation efforts.
- The third written statement contained nonpublic, incriminating details not publicly known, which prosecutors later used to indict and charge Halsey with the crimes.
- A prosecutor relied on the confession to file charges, acknowledging the confession significantly contributed to his decision to prosecute Halsey.
- DNA testing in 2006 exonerated Halsey, showing he did not contribute to Tina’s or Tyrone’s crimes, and pointing to Hall as the offender.
- The district court granted summary judgment on multiple claims, but on appeal the Third Circuit reversed, recognizing a standalone due-process claim for fabrication of evidence and addressing malicious-prosecution and coercion claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can fabrication of evidence support a standalone due-process claim? | Halsey argues fabrication violated due process; independent of malicious prosecution. | Fabrication is actionable only as part of malicious-prosecution claim. | Yes; fabrication can be standalone due-process claim. |
| Was the fabrication causally linked to the prosecution and sufficient for lack of probable cause? | Fabricated confession tainted the initiation of the case, undermining probable cause. | Prosecutor’s independent decision could still show probable cause. | Disputed causation; summary judgment on causation should not have been granted. |
| Did the record create a genuine dispute about coercion in obtaining the confession? | Interrogation tactics overbore Halsey's will, producing an involuntary confession. | Miranda warnings and lack of obvious threats negate coercion. | Yes; summary judgment on coercion was improper; coercion could be found. |
Key Cases Cited
- Johnson v. Knorr, 477 F.3d 75 (3d Cir. 2007) (standards for evaluating fabrication and malicious-prosecution claims)
- Ricciuti v. N.Y.C. Transit Auth., 124 F.3d 123 (2d Cir. 1997) (fabrication of evidence and due process concerns)
- Miller v. Pate, 386 U.S. 1 (U.S. 1967) (due-process limits on state-conduct in prosecutions)
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (duty to disclose exculpatory evidence)
- Devereaux v. Abbey, 263 F.3d 1070 (9th Cir. 2001) (clear warning for standing-alone fabrication claims)
- Wyatt v. Cole, 504 U.S. 158 (U.S. 1992) (deterrence rationale for §1983 remedies)
- Yeager v. United States ex rel. Johnson, 327 F.2d 311 (3d Cir. 1963) (interrogation sequence and confession voluntariness considerations)
- Livers v. City of Montgomery, 700 F.3d 340 (8th Cir. 2013) (coercion and false-confession considerations in coercion claims)