Hart v. Mannina
992 F. Supp. 2d 896
S.D. Ind.2014Background
- Hart sues IMPD officers Mannina and Moore, and supervisors Breedlove, Kelly, and Benjamin, in a third amended complaint asserting Fourth and Sixth Amendment claims and Monell theories.
- Defendants move for summary judgment; the court grants in full the motion on all counts.
- The Miller Incident (Nov. 3, 2008) left Richard Miller dead; multiple witnesses identified Hart as the shooter over weeks of investigation.
- Hart was arrested Dec. 3, 2008, after four independent eyewitness identifications; later related leads tainting a co-defendant Swavely led to dismissal of Swavely’s charges.
- Hart’s trial was continued 363 days; evidence included video, affidavits, and later affidavits from witnesses and Robinson; Lucky Shift footage was destroyed after filming.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was Mannina’s probable cause affidavit truthful and complete? | Hart contends identifications were unreliable and exculpatory facts were omitted. | Mannina did not knowingly misstate facts; no collusion or coaching shown; omissions did not negate probable cause. | No reckless disregard; affidavit supported probable cause. |
| Did Hart have probable cause for arrest based on eyewitness identifications? | Hart argues identifications were unreliable and tainted. | Four independent identifications established probable cause; credibility of witnesses is for jury only if facts show unreliability. | Probable cause existed; arrest lawful. |
| Did Hart’s speedy trial rights violate the Sixth Amendment? | Delays and ongoing detention violated Hart’s right to speedy trial. | Once charges were dismissed, speedy trial rights do not apply; monetary damages are not available for this claim. | Hart’s Sixth Amendment claim failed; no speedy-trial violation. |
| Can Monell claims against the City/Department survive without underlying constitutional violations by officers? | City/Department liable for policy or failure to train from Hart’s alleged violations. | No underlying constitutional violations by the officers; Monell claims fail. | Monell claims dismissed; no municipal liability. |
Key Cases Cited
- Hemsworth v. Quotesmith.com, Inc., 476 F.3d 487 (7th Cir.2007) (standard for summary judgment burden and view of record in the nonmovant's favor)
- Zerante v. DeLuca, 555 F.3d 582 (7th Cir.2009) (court views record in light most favorable to nonmovant)
- Ritchie v. Glidden Co., 242 F.3d 713 (7th Cir.2001) (court not required to scour record to defeat summary judgment)
- Doyle v. Camelot Care Centers, Inc., 305 F.3d 603 (7th Cir.2002) (personal liability required for §1983; those not personally involved not liable)
- Betker v. Gomez, 692 F.3d 854 (7th Cir.2012) (reckless disregard for truth in Franks-like context)
- Knox v. Smith, 342 F.3d 651 (7th Cir.2003) (standard for reckless disregard)
- Franks v. Delaware, 438 U.S. 154 (Supreme Court 1978) (false statements in warrant affidavits; materiality)
- Thomas v. Cook Cnty. Sheriff’s Dep’t, 604 F.3d 293 (7th Cir.2010) (Monell liability when officer actions do not create inconsistent verdicts)
- United States v. Samples, 713 F.2d 298 (7th Cir.1983) (speedy trial considerations after charges dismissed)