Johnny Briscoe v. County of St. Louis, Missouri
690 F.3d 1004
8th Cir.2012Background
- Briscoe sued Hollandsworth, Deen, Webb, and St. Louis County under §1983 for wrongful conviction and delayed exoneration.
- District court dismissed County and granted summary judgment to officers; Briscoe appealed.
- R.T. identified Briscoe in photo lineup and live lineup despite lineup nonconformities; Briscoe was convicted in 1983.
- A December 4, 1982 encounter involving a potential suspect Smith at R.T.’s apartment raised questions about exculpatory evidence.
- Post-conviction DNA testing in 2001–2002 exonerated Briscoe and identified Smith as a possible contributor; Briscoe later obtained relief due to exculpatory DNA evidence.
- Briscoe moved to amend and to alter judgment based on a post-judgment affidavit about an officer’s affair with the victim; district court denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Due process violation from unduly suggestive identifications | Briscoe argues lineups were unduly suggestive | Officers argue identifications were reliable despite suggestiveness | No due process violation; identifications reliable enough under totality of circumstances |
| Concealment of exculpatory evidence by Hollandsworth | Hollandsworth knew exculpatory value of Smith’s visit | No knowledge of exculpatory value; not shown in bad faith | No failure to preserve exculpatory evidence; no bad-faith withholding shown |
| Reckless investigation sufficient for due process claim | Hollandsworth’s conduct constitutes reckless investigation | Negligence alone insufficient for conscience-shocking misconduct | District court did not err; no conscience-shocking misconduct |
| Amendment to add County as defendant futile | County should be subject to Monell liability | Plaintiff cannot establish constitutional violation by officer; amendment futile | Amendment properly denied for futility |
| Rule 59(e) motion based on post-judgment evidence | R.T.’s affidavit about affair could alter result | No due diligence; evidence discovered too late | Rule 59(e) motion denied; no abuse of discretion |
Key Cases Cited
- Manson v. Brathwaite, 432 U.S. 98 (U.S. 1977) (reliability factors for eyewitness identification)
- United States v. Martinez, 462 F.3d 903 (8th Cir. 2006) (unreliability requires both suggestiveness and unreliability)
- Pace v. City of Des Moines, 201 F.3d 1050 (8th Cir. 2000) (core right to a fair trial; sufficiency of reliability shown)
- Arizona v. Youngblood, 488 U.S. 51 (U.S. 1988) (exculpatory evidence; bad faith required for due process claim)
- Wilson v. Lawrence County, 260 F.3d 946 (8th Cir. 2001) (reckless investigation as due process concern)