Harris v. City Of Chicago
1:24-cv-03215
| N.D. Ill. | Dec 18, 2024Background
- Darien Harris was wrongfully convicted in 2011 for the murder of Rondell Moore and spent over 12 years in prison before his conviction was vacated and charges dropped in 2023.
- Harris alleges Chicago police officers fabricated and suppressed evidence, coerced witnesses, and engaged in misconduct to secure his conviction—purportedly pursuant to broader, systemic CPD practices and policies.
- These claims include officers ignoring video evidence contradicting eyewitness statements, coercing a witness to identify Harris, and suppressing exculpatory evidence.
- The complaint includes claims under 42 U.S.C. § 1983 for fabrication of evidence, suppression of evidence, deprivation of liberty, failure to intervene, conspiracy, and Monell claims against the City, as well as state law claims.
- Defendants moved to dismiss several claims, including the Monell claim against the City, IIED (intentional infliction of emotional distress), deprivation of liberty under the Fourteenth Amendment, and claims for respondeat superior and indemnification.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Deprivation of liberty (14th Amendment) | Harris asserts violations of both 4th and 14th Amendments. | Only the 4th applies for pretrial detention per Lewis v. City of Chicago. | Dismissed under 14th, allowed under 4th Amendment |
| Monell claim (policy/practice liability) | CPD had a widespread custom of misconduct affecting others. | Allegations are boilerplate, not sufficiently specific or current. | Dismissed without prejudice |
| IIED statute of limitations | Claim timely; accrual postponed until conviction vacated. | Claim barred by one-year limitation from time of arrest. | Not time-barred; motion denied |
| Respondeat superior & indemnification | Survive as long as any claims against officers remain. | Should be dismissed if claims against officers dismissed. | Motion denied |
Key Cases Cited
- Lewis v. City of Chicago, 914 F.3d 472 (7th Cir. 2019) (held § 1983 claims for unlawful pretrial detention rest on the 4th, not 14th, Amendment)
- Monell v. Dep’t of Social Services of City of New York, 436 U.S. 658 (U.S. 1978) (established municipal liability standards under § 1983)
- McDonough v. Smith, 588 U.S. 109 (U.S. 2019) (addressed accrual of fabricated evidence claims, assumed without deciding 14th Amendment right involved)
- Parish v. City of Elkhart, 614 F.3d 677 (7th Cir. 2010) (statute of limitations for IIED under Heck v. Humphrey runs from exoneration, not arrest)
- Heck v. Humphrey, 512 U.S. 477 (U.S. 1994) (bar on certain civil claims until criminal conviction is overturned)