Aleman v. Village of Hanover Park

In section 1983 action alleging that defendants-various police officers and Village violated plaintiff's 4th Amendment rights by subjecting him to two separate false arrests for murder of infant, Dist. Ct. did not err in granting summary judgment in favor of two officers, as well as City, with respect to first arrest, after finding that said arrest was supported by probable cause where: (1) plaintiff, who admitted to shaking infant, was last person to have custody of infant prior to his death; and (2) hospital personnel had indicated to police that infant had been victim of shaken-baby syndrome. However, as to subsequent second arrest arising out of same incident, Dist. Ct. erred in granting summary judgment as to one defendant-officer where record showed that: (1) said officer had provided false statements about infant to pathologist, who could have rendered evaluation exonerating plaintiff had he known true facts; and (2) said defendant had obstructed investigation of infant's mother, who was more likely culprit in infant's death and who had history of domestic violence. Moreover, Dist. Ct. erred in granting summary judgment as to two other defendant police officers who continued to interrogate plaintiff at police station in violation of plaintiff's Miranda rights by badgering plaintiff to waive said rights after plaintiff had invoked right to counsel. Said defendants also improperly induced plaintiff to confess to crime by lying to plaintiff about substance of medical report regarding cause of infant's death.