Cairel v. Alderden
2016 U.S. App. LEXIS 8354
| 7th Cir. | 2016Background
- Jan. 24, 2007: Jeremy Cairel and Marvin Johnson were stopped during lawful car repossessions; robbery victims were brought to the scene and identified them, leading to arrests.
- At the station, Cairel gave written confessions implicating himself (and referencing others); detectives reported Johnson also confessed (Johnson later pled guilty to avoid jail).
- An alibi from co-worker Eric Moore and company repossession records cast doubt on the identifications; other investigative developments (including arrest of a separate suspect) further weakened the prosecutions.
- Charges were dismissed for Cairel over a year later; Johnson withdrew his guilty plea and served one month of probation.
- Plaintiffs sued detectives under 42 U.S.C. § 1983 (fabrication of evidence, suppression of exculpatory evidence, coercive interrogation) and under Illinois law (malicious prosecution, intentional infliction of emotional distress).
- District court granted summary judgment for defendants; the Seventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Fabrication of evidence (false confessions / IDs) | Fabricated Johnson confession and tainted IDs deprived them of liberty without due process | Even if fabrication occurred, plaintiffs were released on bond and not sufficiently deprived of liberty to state a due‑process fabrication claim | Affirmed: no deprivation of liberty (Saunders‑El controlling) |
| Brady / nondisclosure of alibi evidence | Detectives concealed Moore’s alibi and repossession records from prosecutors and plaintiffs, causing liberty deprivation | Reports and alibi information were provided to prosecutors; plaintiffs knew Moore and could access alibi evidence; neither was deprived of pretrial liberty | Affirmed: no concealed evidence and no liberty deprivation from any nondisclosure |
| Coercive interrogation (substantive due process) | Cairel is cognitively impaired; interrogation tactics (promises, pressure) shocked the conscience | Interrogation used ordinary tactics; Cairel appeared to participate and affirmed he was treated well | Affirmed: no conscience‑shocking conduct; summary judgment proper |
| State claims: malicious prosecution & IIED | Malicious prosecution: absence of probable cause and malice; IIED: interrogation was extreme and outrageous, causing severe distress | Probable cause existed based on victims’ identifications and Cairel’s written statements; interrogation was ordinary law‑enforcement conduct and not extreme | Affirmed: probable cause defeats malicious prosecution; IIED fails — conduct not extreme or outrageous |
Key Cases Cited
- Miller v. Gonzalez, 761 F.3d 822 (7th Cir. 2014) (standard of review for summary judgment)
- Anderson v. Liberty Lobby, 477 U.S. 242 (U.S. 1986) (summary judgment and evidence viewed in light most favorable to nonmoving party)
- Saunders‑El v. Rohde, 778 F.3d 556 (7th Cir. 2015) (fabrication‑of‑evidence claim requires deprivation of liberty)
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution must disclose material exculpatory evidence)
- Armstrong v. Daily, 786 F.3d 529 (7th Cir. 2015) (civil Brady claim requires showing that nondisclosure caused a liberty deprivation)
- Fox v. Hayes, 600 F.3d 819 (7th Cir. 2010) (conscience‑shocking interrogation standard)
- Rochin v. California, 342 U.S. 165 (U.S. 1952) (extreme government conduct that shocks the conscience)
- Askew v. City of Chicago, 440 F.3d 894 (7th Cir. 2006) (eyewitness identifications can provide probable cause despite inconsistencies)
- Newsome v. McCabe, 256 F.3d 747 (7th Cir. 2001) (federal malicious‑prosecution claims precluded where state law remedies adequate)