Shawn Massey v. J.J. Ojaniit, 2014 U.S. App. LEXIS 13838

Massey was released after a North Carolina court struck five 1999 verdicts related to his case.
Massey sued Charlotte-Mecklenburg Police Officers Ojaniit, Esposito, and Ledford under § 1983 and state law claims for fabricating evidence and causing his long incarceration.
The district court granted Rule 12(c) judgments on the pleadings against all three defendants, granting qualified immunity to Ojaniit and Esposito and dismissing Ledford (with Massey not objecting to Ledford).
Key trial witnesses at Massey’s 1999 trial included Wood, Savall, Pride, and the two officers; the trial centered on eyewitness identifications and Pride’s statements about braids.
Duke Clinic investigation in the mid-2000s uncovered hair-length inconsistencies and Wood’s misgivings about her identification; in 2010 the state court set aside the verdicts and ordered Massey released.
Massey appeals only as to Ojaniit and Esposito; Ledford’s dismissal is considered a waiver doctrine issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ledford is properly appealable	Massey preserved error on Ledford appeal	Massey waived appeal by not objecting to Ledford ruling	Appeal as to Ledford dismissed
Whether the district court properly granted Rule 12(c) judgments for Ojaniit and Esposito	Allegations state plausible §1983 violations and fabrications affected convictions	Evidence, including public trial transcript, and qualified immunity defeat §1983 claims	Grants affirmed; no plausible §1983 claims stateable against Ojaniit or Esposito
Whether the §1983 due process claim (Count I) against Esposito survives	Fabrication of Pride’s braid description caused conviction	Fabrication not a but-for or proximate cause; no plausible nexus to conviction	Claim fails; no but-for/proximate causation established
Whether the §1983 false arrest/malicious prosecution claim (Count II) survives	Fabrications rendered arrest probable cause invalid	Grand jury indictment and other identifications show probable cause remained	Probable cause not defeated by fabrications; claim fails
Whether the state-law claims (Counts IV–V) survive	Fabrication supports obstruction/false imprisonment/malicious prosecution	Evans controls; no NC common-law obstruction/false imprisonment liability for officers here	State claims dismissed

Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified immunity framework)
Pearson v. Callahan, 555 U.S. 223 (2009) (modifies timing of immunity analysis)
Edwards v. City of Goldsboro, 178 F.3d 231 (4th Cir. 1999) (Rule 12(b)(6) standard applied to Rule 12(c))
Mylan Labs., Inc. v. Matkari, 7 F.3d 1130 (4th Cir. 1993) (treats Rule 12(c) like Rule 12(b)(6))
Blankenship v. Manchin, 471 F.3d 523 (4th Cir. 2006) (limits consideration to properly admitted exhibits)
Clatterbuck v. City of Charlottesville, 708 F.3d 549 (4th Cir. 2013) (public records may be considered with favorable view to plaintiff)
Philips v. Pitt Cnty. Mem’l Hosp., 572 F.3d 176 (4th Cir. 2009) (judicial notice of public records; integral exhibits)
Evans v. Chalmers, 703 F.3d 636 (4th Cir. 2012) (limits of officer liability where other actors intervene)
Durham v. Horner, 690 F.3d 183 (4th Cir. 2012) (grand jury indictment does not shield officer from liability for deliberate fabrication)
Halsey v. Pfeiffer, 750 F.3d 273 (3d Cir. 2014) (due process versus Fourth Amendment scope in post-arrest context)
Washington v. Wilmore, 407 F.3d 274 (4th Cir. 2005) (due process right not to be deprived by fabrication of evidence)
Zahrey v. Coffey, 221 F.3d 342 (2d Cir. 2000) (fabrication must lead to loss of liberty for due process claim)
Gerstein v. Pugh, 420 U.S. 103 (1975) (grand jury indictment conclusively determines probable cause in some contexts)