Mary Tatum v. Steven Moody
768 F.3d 806
9th Cir.2014Background
- Moody and Pulido allegedly withheld or concealed exculpatory evidence pointing to Walker’s innocence.
- Evidence showed a continuing demand-note robbery spree after Walker’s arrest and Smith’s later confession/arrest.
- Moody and Pulido allegedly misrepresented that the spree ended with Walker’s arrest in reports relied on by prosecutors.
- Walker remained in pretrial detention for about 27 months before charges were dropped.
- District court instructed the jury on due process and deliberate-indifference standards; jury found in Walker’s favor and awarded damages.
- Court addresses whether post-arrest detention and disclosure failures violate due process under §1983 and whether error was harmless.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether due process protects prolonged pretrial detention for withholding exculpatory evidence | Walker’s extended detention violated due process | Due process not triggered in pretrial context here | Yes, due process protection applies to prolonged detention via withholding evidence |
| Whether Fourth Amendment analysis governs post-arrest detention claims | §1983 claim falls under due process, not Fourth Amendment | Fourth Amendment controls detention claims | No; due process governs post-arrest detention in this context |
| Whether failure to disclose exculpatory evidence satisfies deliberate indifference standard | Silence on exculpatory evidence breached duty to prosecutors | No due process violation without impact on trial/proceedings | Yes; deliberate indifference established by withholding highly material exculpatory evidence |
| Whether instructional errors about the due process standard were harmless | Instructional error affected outcome | Harmless error standard applies | Harmless; substantial rights not prejudiced given lapse in evidence disclosure |
| Whether the district court properly awarded attorney’s fees | Prevailing party entitlement under 42 U.S.C. §1988 | No error in fees order | affirmed the fees |
Key Cases Cited
- Rivera v. County of Los Angeles, 745 F.3d 384 (9th Cir. 2014) (post-arrest detention analyzed under due process, not Fourth Amendment)
- Baker v. McCollan, 443 U.S. 137 (U.S. 1979) (pretrial detention may violate due process after time or procedures vary)
- Lee v. City of Los Angeles, 250 F.3d 668 (9th Cir. 2001) (continued detention after entitlement to release can violate due process)
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution must disclose exculpatory evidence to protect due process)
- Russo v. City of Bridgeport, 479 F.3d 196 (2d Cir. 2007) (willful failure to disclose exculpatory evidence may implicate due process)
- Jones v. City of Chicago, 856 F.2d 985 (7th Cir. 1988) (police officers’ duty to disclose exculpatory evidence to prosecutors when instrumental in continued confinement)
- Stoot v. City of Everett, 582 F.3d 910 (9th Cir. 2009) (immunity analysis related to duties of officers in disclosure contexts)
- Gantt v. City of Los Angeles, 717 F.3d 702 (9th Cir. 2013) (definition of deliberate indifference in due process context)