Coleman v. City of Peoria

Federal 7th Circuit Court
Civil Court
Section 1983 Action
Citation
Case Number: 
No.18-1742
Decision Date: 
May 24, 2019
Federal District: 
C.D. Ill.
Holding: 
Affirmed

Dist. Ct. did not err in granting defendants-police officials’ motion for summary judgment in section 1983 action, alleging that defendants deprived plaintiff of fair trial by eliciting false testimony through coercive interrogation techniques and suggestive identification procedures and by suppressing impeachment evidence that led to his wrongful conviction that was eventually overturned. Although one witness reluctantly identified plaintiff as one of several culprits, plaintiff failed to show that defendants knew that said identification was false, even though coercive techniques were used, since coercive testimony is not necessarily fabricated. Moreover, one victim’s identifications of plaintiff as culprit were sufficiently reliable for defendants to rely on them, where victim stated that she observed plaintiff’s face for three minutes during incident that led to charged offenses and had been previously acquainted with plaintiff for number of years. Also, plaintiff failed to establish that withheld line-up photo that showed discrepancy in wristbands worn by line-up participants was material or played any role in witness’s identification of plaintiff as culprit, where witness did not notice wristbands, but based identification on her recognition of defendant’s face.