Harold Hall v. City of Los Angeles
697 F.3d 1059
| 9th Cir. | 2012Background
- In 1984 Hall, aged 18, testified in the 54th Street murder case, leading to protection concerns for his safety.
- Between the preliminary hearing and Hall’s 1985 arrest for robbery, Detective Dufort maintained contact with Hall, forming a problematic relationship.
- Neighbors near the Duncan-Rainey murders (1985) were curious about the case; Powell allegedly implicated Hall via other suspects and jailhouse informants.
- Arneson and Crocker, detectives, questioned Hall in the Duncan-Rainey investigation without advising Miranda rights, using coercive methods.
- Hall confessed after prolonged interrogation; the confession and falsified documents from jailhouse informants formed the trial’s core evidence.
- Hall was convicted of the Duncan-Rainey murders and spent nineteen years in prison; habeas relief was granted in 2004 due to due process violations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Devereaux prong (2) applies to coercive interrogation claims. | Hall argues coercive interrogation yields fabrication of evidence under Devereaux prong (2). | Appellees contend Fifth Amendment governs coercive confession; Devereaux prong (2) does not apply to suspect interrogations. | Devereaux prong (2) does not apply; Fifth Amendment governs coercive confession claim. |
| Whether Hall's claim is cognizable under the Fifth Amendment or the Fourteenth Amendment. | Hall seeks relief under Devereaux prong (2) but contends Fourth/Fourteenth claims. | Appellees argue the claim fits Fifth Amendment coercion, not Fourteenth due process. | Coercive interrogation is Fifth Amendment; Fourteenth claim not cognizable here. |
| Whether the district court abused its discretion by denying leave to amend to add a Fifth Amendment claim. | Amendment would have allowed explicit Fifth Amendment claim; district court erred in denying. | Amendment would prejudice and delay trial; local rules were not followed; delay was undue. | Discretionary denial was an abuse; remand to permit amendment is warranted to address manifest injustice. |
| Whether the district court properly granted qualified immunity to Arneson and Crocker. | Coercive interrogation violated clear constitutional rights; officers knew or should have known. | Right to fabricated evidence claim not cognizable under Devereaux prong (2); right not clearly established for this claim. | Qualified immunity affirmed; court did not need to reach whether the right was clearly established. |
Key Cases Cited
- Devereaux v. Abbey, 263 F.3d 1070 (9th Cir. 2001) (fabrication-of-evidence under due process via coercive investigation not applied to suspects)
- Hall v. Dir. of Carr., 343 F.3d 976 (9th Cir. 2003) (habeas decision on falsified evidence; per curiam)
- Pyle v. Kansas, 317 U.S. 213 (Supreme Court 1942) (perjured testimony as due process violation)
- Albright v. Oliver, 510 U.S. 266 (1994) (explicit textual source governs coercive interrogation claims; Fifth Amendment applies)
- Crowe v. County of San Diego, 608 F.3d 406 (9th Cir. 2010) (coercive interrogation and Fifth Amendment issues discussed)
- Collins v. City of Harker Heights, 508 U.S. 115 (1992) (explicit-textual source governs due process questions)