Daniel Jackson v. Shawn Curry, 888 F.3d 259

Background

On Aug. 29, 2009 Clifford Harvey Jr. was killed; no weapon or eyewitness identified at scene; a witness (Eibeck) later identified Daniel Jackson in a photo lineup about six months later.
Police arrested Jackson without a warrant; he was intoxicated and interrogated on video for ~2+ hours by Officers Curry and McDaniel; Jackson collapsed near the end and was taken to a hospital.
During interrogation officers allegedly lied about evidence, suggested self‑defense facts, discouraged silence, and McDaniel allegedly warned Jackson a biased jury would convict him because he is a young Black man.
Jackson was convicted at trial based on the identification and interrogation video; Illinois appellate court later reversed the conviction for lack of probable cause.
Jackson sued the officers claiming a coerced confession in violation of the Fifth Amendment; the district court denied the officers’ qualified‑immunity dismissal motion, and the officers appealed.
The Seventh Circuit dismissed the interlocutory appeal for lack of jurisdiction because the issues presented were not pure legal questions suitable for immediate review of a qualified immunity denial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court should have reviewed the interrogation video at pleadings stage	Jackson: accept complaint facts; video does not defeat allegations of impairment and coercion	Officers: video shows no impairment/susceptibility and no unconstitutional tactics; district court should have viewed it	Court: No jurisdiction to review refusal to consider video at pleadings stage; factual disputes remain and video is not dispositive like Scott
Whether McDaniel’s race‑related comments were clearly established constitutional violations	Jackson: comments plus totality (intoxication, lies, refusal to allow counsel, collapse) plausibly show coercion	Officers: comments are generalized and not clearly prohibited; no closely analogous precedent	Court: District court considered comments as part of totality; denial raised no pure legal question about a discrete ruling on the comments, so no jurisdiction
Whether admission of the confession at state trial was a superseding cause entitling officers to immunity	Jackson: confession was coerced; state admission does not absolve officers	Officers: state court’s admission was independent superseding cause	Court: Superseding‑cause argument not a pure legal question in this context; no jurisdiction
Whether the denial of qualified immunity here presents a pure legal question allowing immediate appeal	Jackson: facts accepted at pleading stage plausibly show constitutional violation	Officers: denial involves legal issues about clearly established law and should be reviewable now	Court: Because the district court relied on pleaded facts and inferences and many disputed factual matters remain, the appeal does not present a pure legal question; appellate jurisdiction lacking

Key Cases Cited

Harlow v. Fitzgerald, 457 U.S. 800 (1982) (defines qualified immunity standard and purpose)
Mitchell v. Forsyth, 472 U.S. 511 (1985) (qualified immunity includes entitlement not to stand trial)
Pearson v. Callahan, 555 U.S. 223 (2009) (two‑step qualified immunity framework)
Scott v. Harris, 550 U.S. 373 (2007) (video evidence may conclusively resolve factual dispute when it utterly contradicts plaintiff’s account)
Johnson v. Jones, 515 U.S. 304 (1995) (defendants cannot immediately appeal disputed factual determinations on qualified immunity)
Armstrong v. Daily, 786 F.3d 529 (7th Cir. 2015) (qualified immunity denial is appealable only when it presents a pure legal question)
Hurt v. Wise, 880 F.3d 831 (7th Cir. 2018) (limits on appellate jurisdiction over factual disputes in qualified immunity appeals)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (standards for pleadings and what constitutes a final decision for appeal)
Chavez v. Martinez, 538 U.S. 760 (2003) (use of coerced confessions at trial can violate Fifth Amendment)