Jackson v. Curry

Ct. of Appeals lacked jurisdiction to consider appeal by defendants-police officers of Dist. Ct.’s order denying their motion to dismiss on plaintiff’s section 1983 action alleging that defendants coerced plaintiff into making false confession to crime, even though defendants asserted that they were entitled to qualified immunity with respect to plaintiff’s action. Although collateral-order doctrine permits immediate appeals from denials of motions to dismiss on grounds of qualified immunity at pleading stage where said motions raise only pure legal questions, collateral-order doctrine did not apply because instant appeal raised questions of fact that concerned interpretations regarding contents of videotaped confession, as well as factual issue regarding whether certain statements made to plaintiff during his interrogation were coercive.