Patrick v. City of Chicago

Record contained sufficient evidence to support jury’s $13.3 million verdict in favor of plaintiff in his section 1983 action, alleging that his constitutional rights were violated where defendants: (1) used his coerced confession to obtain convictions on murder charges that were eventually vacated via state’s motion after plaintiff had served 21 years on life sentence; (2) fabricated evidence against plaintiff and conspired to violate his constitutional rights; and (3) failed to intervene to prevent certain constitutional violations. While defendants argued that case should have been dismissed as sanction for plaintiff giving two false statements in his deposition, Dist. Ct. did not abuse its discretion in not dismissing case, where plaintiff’s false statements about seeing third-party get arrested or about fact that he had never spoken to different individual did not concern core issues in plaintiff’s case and were otherwise fully exposed at trial. Also, Dist. Ct. did not err in admitting plaintiff's certificate of innocence, since said certificate was highly relevant to plaintiff’s malicious prosecution claim, and jury was otherwise instructed not to decide whether plaintiff had committed charged offenses in criminal case. Also, while Dist. Ct. gave jury fabrication of evidence instruction that improperly failed to explain that plaintiff had burden to prove that said evidence was used at trial and was material to his conviction, said error was harmless, where record showed that plaintiff’s coerced confession and defendants’ fabricated line-up report were actually used at trial, and that said evidence was material to his convictions.