Opinion

J. Gilliam v. Kenneth Sealey

  • 932 F.3d 216
Court
Court of Appeals for the Fourth Circuit
Filed
Jul 30, 2019
Status
Published
Author
Richardson
On the bench
Niemeyer, Thacker, Richardson
Cited by
79 cases

holding that confessions by “serious[ly] intellectual[ly] disabled[]” suspects were involuntary in combination with numerous other factors, and reaching that conclusion “in light of all of the above”

How later courts described this case

  • holding that confessions by “serious[ly] intellectual[ly] disabled[]” suspects were involuntary in combination with numerous other factors, and reaching that conclusion “in light of all of the above”
  • holding “there can be no reasonable dispute . . . that an individual has a constitutional right not to be deprived of liberty as a result of the intentional, bad-faith withholding of evidence by an investigating officer”
  • finding that plaintiff had adequately alleged bad faith in light of allegations that the defendants “intentionally fabricated, obscured, and failed to disclose the most relevant and exculpatory evidence in the case”
  • recognizing clearly established “constitutional rights not to be imprisoned and convicted based on coerced, falsified, and fabricated evidence or confessions”

Written by the judges who cited it.

The opinion

RICHARDSON, Circuit Judge, concurring in part and dissenting in part:

I agree that the Plaintiffs' Fourth Amendment claims should survive summary

judgment and that their Fifth Amendment claims arising from their confessions and Mary Richards's statement should likewise go to trial. However, on the remaining due process claims-the officers' failure to investigate Artis, the coercive questioning of Sinclair, and the failure to disclose their impressions of Artis as a suspect-the Plaintiffs fail to articulate the violation of a constitutional right. And even if they could, these alleged due process rights were not clearly established in 1983. I would therefore reverse on these remaining Fifth Amendment claims.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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