Cairel v. Alderden

Dist. Ct. did not err in granting defendants-police officials’ motion for summary judgment in section 1983 action arising out of arrests/failed criminal prosecution of plaintiffs on robbery charges, where plaintiffs alleged that defendants violated their due process rights by: (1) fabricating one plaintiff’s alleged confession to robbery charges; (2) failing to disclose potential alibi witness; and (3) coercing false confession from other plaintiff. Record showed that plaintiffs were bailed out of jail shortly after their arrests, and thus plaintiffs could not show that they were deprived of substantial liberty so as to support instant due process claim. Also, plaintiffs could not establish that defendants concealed any unknown witness that would have supported their alibi claim. Moreover, plaintiffs failed to show that interrogation tactics used by defendants to generate instant false confession “shocked the conscience,” in spite of allegation that instant plaintiff had learning disability, since instant plaintiff fully participated in interrogation, corrected errors in written confession and stated that he had been treated well.