Priscilla Everette-Oates v. Lolita Chapman, 20-1093

Background

Priscilla Everette-Oates, then-mayor of Princeville, NC, was investigated for misuse of a town credit card after an LGC audit and State Auditor review identified questionable expenditures.
State SBI agent Lolita Chapman conducted the investigation, centered on charges lacking receipts and charges described as for an "Economic Development Committee." Chapman was the sole grand jury witness leading to a 17-count indictment for embezzlement.
The LGC retained Princeville’s financial records; defense and prosecutors later inspected a larger set of documents, locating a folder labeled "Economic Development Committee" and receipts for the mayor that had not been previously produced.
Prosecutors dismissed the indictment after discovering evidentiary and credibility problems; Everette-Oates then sued under 42 U.S.C. § 1983 alleging Chapman fabricated and concealed evidence in grand jury testimony and that Chapman and several state officials conspired to cause false testimony.
The district court allowed Fourth Amendment claims for alleged fabrication/concealment of grand-jury evidence and a related conspiracy claim to proceed past pleading, but later granted summary judgment to defendants, principally on absolute immunity grounds and for lack of material falsification supporting a Fourth Amendment violation.
The Fourth Circuit affirmed: Chapman is immune under Rehberg for testimony and related preparation; the record shows Chapman turned over her investigative file and conflicting evidence, and probable cause remained; the conspiracy claim failed as the underlying constitutional violation could not be shown.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Chapman's grand-jury testimony or related preparatory acts are actionable under § 1983	Everette-Oates: Chapman fabricated/ concealed material evidence in grand-jury testimony and in communications with prosecutors	Chapman: Grand-jury testimony and preparatory communications are absolutely immune under Rehberg	Court: Rehberg grants absolute immunity for testimony and preparatory activity; claims based on that testimony are barred
Whether Chapman deliberately falsified or concealed evidence about the Economic Development Committee such that the Fourth Amendment was violated	Everette-Oates: Chapman hid or fabricated evidence to make it appear no Committee existed, inducing indictment	Defendants: Chapman provided prosecutors her full investigative file, which included both supporting and contrary materials; no deliberate concealment	Court: Record undisputed that Chapman turned over mixed evidence; no genuine issue that she deliberately concealed or fabricated, and probable cause remained
Whether any withheld/falsified evidence was material to probable cause	Everette-Oates: Documents found at LGC show withheld exculpatory proof and were material to probable cause	Defendants: Even accounting for all conflicting evidence, sufficient basis for probable cause existed	Court: Plaintiff did not contest district court finding that probable cause would remain; materiality requirement not met
Whether the conspiracy claim survives summary judgment	Everette-Oates: Chapman and officials conspired to cause false grand-jury testimony, depriving her of constitutional rights	Defendants: No underlying constitutional violation and no evidence of a conspiratorial agreement or overt acts	Court: Conspiracy claim fails because no underlying Fourth Amendment violation shown and record lacks evidence of a mutual unlawful objective

Key Cases Cited

Rehberg v. Paulk, 566 U.S. 356 (2012) (absolute immunity for grand-jury witnesses and related preparatory activities)
Durham v. Horner, 690 F.3d 183 (4th Cir. 2012) (deliberate falsification of evidence can negate probable cause for malicious prosecution claims)
Massey v. Ojaniit, 759 F.3d 343 (4th Cir. 2014) (false statements/omissions violate Fourth Amendment only if material to probable cause)
Evans v. Chalmers, 703 F.3d 636 (4th Cir. 2012) (elements of malicious prosecution include seizure pursuant to process unsupported by probable cause)
Miller v. Prince George's County, 475 F.3d 621 (4th Cir. 2007) (reckless or deliberate misleading of grand jury may state Fourth Amendment claim)
Hinkle v. City of Clarksburg, 81 F.3d 416 (4th Cir. 1996) (requirements for § 1983 civil conspiracy)
Manuel v. City of Joliet, 137 S. Ct. 911 (2017) (discussion of pretrial restraints and the relationship between Fourth Amendment and due process claims)