187 F. Supp. 3d 939
N.D. Ill.2015Background
- In 1983 Stanley Wrice was convicted of rape after allegedly confessing following torture by Area 2 officers John Byrne and Peter Dignan; he received a 100-year sentence.
- Wrice and others later alleged the confessions and key witness statements (notably Bobby Joe Williams) were obtained through torture under Commander Jon Burge’s supervision.
- In December 2013 a state judge granted Wrice a new trial, finding Byrne and Dignan lied at the suppression hearing about torturing Wrice; the prosecution later dismissed the charges.
- Wrice filed § 1983 and state-law claims against the two officers, Burge, supervising officers (including Leroy Martin), the trial prosecutor Bertina Lampkin, former State’s Attorney and later Mayor Richard M. Daley, several later CPD officials, the City, Cook County, and the Cook County State’s Attorney’s Office.
- The district court (Bucklo, J.) dismissed multiple defendants and claims on immunity, statute-of-limitations, failure-to-state-a-claim, and lack of personal involvement grounds, leaving only limited Brady and coerced-confession § 1983 theories against certain City defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Absolute prosecutorial immunity for trial-related acts (Lampkin) | Lampkin prepared and presented witnesses unfairly and concealed coercion; liable for due-process violations | Lampkin is entitled to absolute immunity for core prosecutorial functions | Granted: Lampkin entitled to absolute immunity for federal and parallel state claims |
| Liability of Richard M. Daley (as State's Attorney and as Mayor) | Daley learned of Burge-era torture and suppressed or failed to investigate it, enabling convictions | As prosecutor Daley has absolute immunity; as Mayor, actions are not plausibly connected to Wrice’s conviction | Granted: Daley dismissed in full (absolute immunity and lack of plausible causal link) |
| Brady/fabrication claim against City/officers for withholding torture of Williams and Wrice | Officers concealed that Williams was tortured; nondisclosure was material Brady evidence; officers fabricated or used coerced statements | Defendants: fabrication claim is really a coercion claim (not actionable as fabrication); some Brady theories untimely or known to prosecution | Mixed: Brady claim as to interrogation of Williams survives; fabrication claim dismissed as coercion, not fabrication |
| Statute of limitations and Heck accrual for coerced-confession and related torts | Coerced-confession claim tolled until conviction set aside; filed timely after 2013 new-trial order | Defendants: claims accrued in 1982–83 and are time-barred (Wallace, accrual rules) | Granted in part/Denied in part: excessive-force/false-arrest/IIED/time-barred; Fifth Amendment coerced-confession claim was Heck-barred until 2013 and survives as timely |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for plausibility)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Imbler v. Pachtman, 424 U.S. 409 (absolute prosecutorial immunity for core advocative functions)
- Van de Kamp v. Goldstein, 555 U.S. 335 (supervisory prosecutors’ absolute immunity re: training/supervision on Giglio/Brady)
- Buckley v. Fitzsimmons, 509 U.S. 259 (limits of prosecutorial immunity where functions are investigative)
- Fields v. Wharrie, 740 F.3d 1107 (7th Cir.) (distinguishing investigative vs prosecutorial acts and immunity)
- Whitlock v. Brueggemann, 682 F.3d 567 (7th Cir.) (fabrication-of-evidence doctrine and police-created evidence liability)
- Petty v. City of Chicago, 754 F.3d 416 (7th Cir.) (coercion vs fabrication distinction; coercion not equivalent to fabrication claim)
- Wallace v. Kato, 549 U.S. 384 (accrual of § 1983 claims for false arrest/imprisonment)
- Heck v. Humphrey, 512 U.S. 477 (bar to § 1983 claims that would imply invalidity of conviction)
- Chavez v. Martinez, 538 U.S. 760 (Fifth Amendment claim typically requires use of compelled statements in a proceeding)