Dist. Ct. did not err in granting defendants-police officials’ motion to dismiss plaintiff’s section 1983 action alleging that defendants violated plaintiff’s 5th and 14th Amendment rights by obtaining confession from him to murder charge, under circumstances where defendants had been aware that he had cognitive impairments, and where said confession was subsequently suppressed and murder charge dropped. Defendants were entitled to qualified immunity, even though plaintiff argued that defendants had coerced his confession, since: (1) whether interrogation tactics are unconstitutionally coercive is inquiry that depends on specific facts of case; and (2) plaintiff failed to present any Supreme Court or Seventh Circuit precedent that puts constitutionality of defendants’ conduct “beyond debate.” Ct. further noted that in Cairel, 821 F.3d 823, it had recently rejected closely similar substantive due process claim based on interrogation of suspect with cognitive disability. Ct. also rejected defendant’s false arrest claim, where plaintiff conceded that defendants had probable cause to arrest him on obstruction charge, and where defendant was charged with murder at time defendant was still in custody on obstruction charge.
Federal 7th Circuit Court
Civil Court
Qualified Immunity