Law School Case Brief
Patterson v. Burge - 328 F. Supp. 2d 878 (N.D. Ill. 2004)
In practical terms, a Brady violation has three components: (1) the evidence at issue must be favorable to the accused, meaning either exculpatory or impeaching; (2) the evidence must have been suppressed by the state, either willfully or inadvertently; and (3) prejudice must have ensued. Though Brady identifies a trial right of the accused, the government's offending conduct may occur before, or after, the criminal trial.
After being convicted for the 1986 murders of Rafaela and Vincent Sanchez and spending 13 years on death row, plaintiff Aaron Patterson was pardoned by Illinois Governor George Ryan on January 10, 2003. Patterson then filed a civil action asserting that the defendants, individually and in conspiracy, violated his rights under the United States Constitution and Illinois state law when they knowingly filed false charges and framed him for the Sanchez murders, tortured and beat him at Chicago Police Department's headquarters, fabricated his "confession" and falsified inculpatory evidence, coerced witnesses to testify against him, gave perjured testimony, published defamatory statements regarding his guilt, and obstructed justice and suppressed exculpatory evidence throughout his suppression hearing, trial, and post-conviction proceedings. The defendants filed a motions to dismiss Patterson's complaint and all of the 14 claims contained therein.
Should the court grant defendants' motion to dismiss the complaint in which plaintiff claims that he was wrongfully tortured, charged, and convicted for murders in violation of his federal constitutional rights, including a § 1983 due process claim?
Yes, in part.
Defendants' motions to dismiss were granted with respect to plaintiff's § 1983 claims for false imprisonment, access to courts, and his Monell claim against defendant county, but defendants' motion to dismiss was denied in part as to, inter alia, plaintiff's § 1983 claims related to his right to a fair trial, coercive interrogation, excessive force, and his Monell claim against defendant city. The district court found that plaintiff had adequately pleaded a § 1983 claim for deprivation of procedural due process against all individual defendants. Further, the court held that the plaintiff had stated common law claims for malicious prosecution, intentional infliction of emotional distress, and conspiracy against each of the individual defendants, such that the defendants city and county state's attorney, as employers of the individual defendants, could be held liable for their actions. Likewise, the § 1983 Monell claims against defendant county state's attorney's office were barred under the Eleventh Amendment and the Monell claims against the defendant county failed because the county was not responsible for the actions of any of the individual defendant state's attorneys. However, the court held that the existence of probable cause for an arrest barred plaintiff's § 1983 false imprisonment claim.
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