Fields v. City of Chicago

Dist. Ct. did not err in granting plaintiff’s Rule 60(b)(2) motion for new trial in plaintiff’s section 1983 action, alleging that defendants-City and certain police officers had fabricated evidence and withheld exculpatory evidence that resulted in plaintiff’s murder conviction. Original trial resulted in $80,000 jury verdict in favor of plaintiff as to one police defendant and verdicts in favor of all other defendants. In support of said motion, plaintiff alleged that he learned within months after original trial in 2014 that key witness for defendants would not be incarcerated until 2027 as represented by defendants during trial, but rather was released from prison in 2014 pursuant to apparent agreement by witness to provide favorable testimony for defendants. As such, plaintiff’s newly discovered evidence regarding witness’s prisoner status cast doubt on credibility of said witness that would have cut at heart of defendants’ case so as to justify Dist. Ct.’s grant of new trial, which subsequently resulted in jury’s award of $22 million in compensatory damages at second trial against two police defendants and defendant City. Also, Dist. Ct. could properly set aside result of first trial under Rule 60(b)(3) based on finding of either fraud, misrepresentation or misconduct arising out of misrepresentation regarding witness’s prisoner status. Dist. Ct. also properly granted plaintiff’s Rule 59(e) motion for new trial with respect to defendant-City after finding that Dist. Ct.’s limitation on discovery unfairly prevented plaintiff from obtaining and investigating “street files” held by police department with respect to other defendants that could have supported plaintiff’s claim that City had custom of wrongdoing that withheld exculpatory evidence contained in said files not only in plaintiff’s case but for other defendants facing criminal charges. Too, record supported jury’s verdict against City in second trial, where plaintiff produced evidence that there was systemic underproduction of exculpatory materials to prosecutors and defense counsel. (Dissent filed.)