Hoskins v. Jason York
6:17-cv-00084
E.D. Ky.Mar 23, 2020Background
- In December 2010 Katherine Mills was found dead and ~ $12,000 from timber sales was missing; KSP Detective Jason York led a long investigation that produced numerous witness statements implicating Amanda Hoskins, Jonathan Taylor, William Lester, and others.
- Investigative tactics included recorded and unrecorded interviews, polygraphs, witness recantations, and suggestive photo procedures; some witnesses later recanted or became unavailable and physical evidence (fingerprints, DNA) did not match the charged suspects.
- In March–April 2012 York sought and obtained arrest warrants; grand jury testimony and a preliminary hearing followed. Charges against Plaintiffs (Hoskins and Taylor) were later dismissed without prejudice (2016) after prosecutors concluded witnesses/evidence were no longer reliable or available.
- Plaintiffs brought a § 1983 and state-law suit alleging (inter alia) malicious prosecution, fabrication of evidence, supervisory liability, failure to intervene, conspiracy, and Monell liability against York and several other officers and Knox County. Plaintiffs later narrowed claims and dismissed various defendants.
- The Court evaluated multiple summary-judgment motions and held that almost all defendants and claims (Pickard, Broughton, Mefford, Joseph, Knox County) are entitled to summary judgment; only malicious-prosecution claims (federal and state) against Jason York individually survive for trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a standalone Fourth Amendment fabrication claim survives independent of malicious prosecution | Plaintiffs: fabrication caused unlawful post-process pretrial detention and is independently actionable under the Fourth Amendment | Defendants: fabrication claim duplicates malicious prosecution; if untainted probable cause existed, fabrication cannot establish a Fourth Amendment violation | Court: Denied an independent §1983 fabrication claim here — fabrication is subsumed by the Fourth Amendment malicious-prosecution (wrongful detention) inquiry because probable-cause causation is dispositive |
| §1983 malicious prosecution (continued detention without probable cause) against York and other officers | Plaintiffs: York fabricated or omitted material evidence, caused/participated in prosecution; dismissal shows lack of probable cause | Defendants: there was probable cause (witness statements, scene facts); many defendants had only peripheral roles or are immune | Court: Triable issues as to York’s role and probable cause — malicious-prosecution claims survive against York; insufficient participation/causation or immunity defeats claims against other officers |
| Supervisory liability / negligent supervision against Joseph | Plaintiffs: Joseph knew or acquiesced in York’s techniques and failed to train/supervise, so is liable | Joseph: she lacked notice/participation and did not take the active unconstitutional steps required for liability; duties limited | Held: No triable evidence of Joseph’s active participation or notice such that supervisory liability or negligent supervision survives; judgment for Joseph |
| Monell and municipal liability of Knox County | Plaintiffs: County had deficient policies/customs and failed to train/supervise, leading to predictable constitutional violations | Knox County: no municipal policy caused the injury; no showing an official with final policymaking ratified misconduct; individual liability not established | Held: Knox County entitled to summary judgment — Plaintiffs failed to show municipal policy, custom, or causation sufficient for Monell liability |
Key Cases Cited
- Manuel v. City of Joliet, 137 S. Ct. 911 (2017) (Fourth Amendment covers post-legal-process detention when legal process was tainted by fabricated evidence)
- Malley v. Briggs, 106 S. Ct. 1092 (1986) (§ 1983 read against tort causation background; liability tied to natural consequences of actions)
- Webb v. United States, 789 F.3d 647 (6th Cir. 2015) (discussing officer participation and fabrication; limits of indictment/probable-cause presumption)
- King v. Harwood, 852 F.3d 568 (6th Cir. 2017) (rebuttable presumption of probable cause where officers knowingly or recklessly presented false statements/evidence)
- Gregory v. City of Louisville, 444 F.3d 725 (6th Cir. 2006) (malicious-prosecution and Brady/fabrication claims analyzed as distinct constitutional injuries)
- Spurlock v. Satterfield, 167 F.3d 995 (6th Cir. 1999) (fabricating probable cause to effect a seizure violates the Fourth Amendment)
- Robertson v. Lucas, 753 F.3d 606 (6th Cir. 2014) (untainted probable cause defeats wrongful-detention Fourth Amendment claim)