Carlton Hart v. Christine Mannina
798 F.3d 578
| 7th Cir. | 2015Background
- In November 2008 a deadly home invasion in Indianapolis left one victim dead and others injured; four surviving eyewitnesses later identified Carlton Hart in photo arrays as one of the shooters.
- Detective Christine Mannina led the investigation; she prepared a probable-cause affidavit relying on four Nov. 22, 2008 identifications and procured an arrest warrant; Hart was arrested Dec. 3, 2008 and detained almost two years before charges were dismissed for insufficient nexus.
- The investigation was filmed for a reality TV show, The Shift; raw video of the Nov. 22 interviews (which contained the unrecorded initial moments) was destroyed by the production company about a month after broadcast.
- Hart sued under 42 U.S.C. § 1983 against Mannina, other detectives, and the City alleging false arrest/false imprisonment, fabrication/omission in the probable-cause affidavit, abuse of process, malicious prosecution, speedy-trial violations, supervisory/Monell liability, and discovery irregularities.
- The district court granted partial judgment on the pleadings for some counts and later granted summary judgment to defendants on the remaining claims; the Seventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for arrest | Hart: identifications were unreliable, coached, and tainted by investigatory misconduct | Defs: four independent eyewitness IDs given to Mannina provided probable cause; no evidence of coaching or knowledge of unreliability | Held: Probable cause existed based on four separate identifications; summary judgment for defendants |
| Truthfulness/material omissions in affidavit | Hart: Mannina knowingly or recklessly omitted/exaggerated facts (e.g., failed tape-recording, Bluiett’s uncertainty, circulation of MySpace video) that would negate probable cause | Defs: omitted facts were immaterial; no evidence Mannina knew IDs were unreliable or that witnesses colluded | Held: No genuine issue that affidavit was false or materially misleading; summary judgment for defendants |
| Spoliation of exculpatory evidence (raw video) | Hart: destruction of Lucky Shift raw footage supports inference of bad-faith spoliation and coaching | Defs: production’s routine destruction; no evidence IMPD caused or knew of destruction; footage had no apparent exculpatory value | Held: No evidence footage was obviously exculpatory or destroyed in bad faith; spoliation claim fails |
| Speedy-trial violation | Hart: nearly two-year pretrial detention violated Sixth Amendment right to speedy trial | Defs: delays were largely the result of defense-requested continuances; Hart never asserted the right | Held: Barker factors weigh against Hart (he moved for continuances and did not assert speedy-trial right); claim fails |
Key Cases Cited
- Manson v. Brathwaite, 432 U.S. 98 (reliability factors for eyewitness ID)
- Neil v. Biggers, 409 U.S. 188 (factors for assessing reliability of identification)
- Perry v. New Hampshire, 565 U.S. 228 (when reliability testing of eyewitness ID is for adversarial process absent police misconduct)
- Franks v. Delaware, 438 U.S. 154 (material false statements/omissions in warrant affidavits)
- Arizona v. Youngblood, 488 U.S. 51 (due-process claim for destroyed evidence requires bad faith)
- California v. Trombetta, 467 U.S. 479 (constitutional duty to preserve evidence with apparent exculpatory value)
- Barker v. Wingo, 407 U.S. 514 (four-factor speedy-trial test)
- Doggett v. United States, 505 U.S. 647 (prejudice presumption for excessive delay)
- Whren v. United States, 517 U.S. 806 (objective reasonableness, motive irrelevant)
- Brigham City v. Stuart, 547 U.S. 398 (Fourth Amendment reasonableness not tied to subjective motive)
- Woods v. City of Chicago, 234 F.3d 979 (single credible eyewitness can supply probable cause)
- Julian v. Hanna, 732 F.3d 842 (availability of federal claims when state remedies are inadequate)