Caldwell v. City of San Francisco

Background

Maurice Caldwell alleged that San Francisco police officers fabricated evidence during the investigation of a 1991 murder. He alleged that former San Francisco police officer Kitt Crenshaw brought him, handcuffed, to a witness’s front door, creating a suggestive “show-up,” and later wrote a false report stating that Caldwell had admitted being at the murder scene. The witness later identified Caldwell, who was arrested, tried, and convicted. Caldwell spent nearly 20 years in prison.

Caldwell was released in 2010 after a state court granted his petition challenging his imprisonment based on ineffective assistance of counsel. In December 2016, the state court concluded that his lawyer had failed to investigate evidence of innocence and that Caldwell had not received a fair trial. The court did not decide Caldwell’s claims of false testimony or actual innocence. Caldwell was not retried, and the charges were dismissed.

Claims and Earlier Proceedings

Caldwell’s remaining claims included a civil-rights claim under 42 U.S.C. Section 1983 against Crenshaw for deliberately fabricating evidence in violation of the Fourteenth Amendment’s due process protection, and a municipal-liability claim against San Francisco. The earlier district-court ruling granted summary judgment to the individual defendants. The Ninth Circuit affirmed the ruling for two officers, reversed it as to Crenshaw, and sent the municipal-liability claim back for further proceedings. The remaining claim addressed in this order was Caldwell’s fabrication-of-evidence claim against Crenshaw.

Motion to Dismiss

Crenshaw and San Francisco moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not adequately state a legal claim. They initially argued that a Supreme Court decision concerning fabricated evidence and pretrial detention meant Caldwell’s claim was actually a Fourth Amendment detention claim and was time-barred because it began when he was arrested and charged. Caldwell clarified that he was not bringing a pretrial-detention claim. The defendants withdrew that argument.

The defendants alternatively argued that Caldwell could not state a Fourteenth Amendment fabrication-of-evidence claim without alleging that the criminal case ended in his favor. The court identified this as the only issue before it.

Court’s Analysis

The court explained that a fabrication-of-evidence claim requires proof that the defendant deliberately fabricated evidence and that the fabrication caused the plaintiff’s loss of liberty. It rejected the defendants’ interpretation of McDonough v. Smith. According to the court, McDonough decided when a fabrication-of-evidence claim begins for statute-of-limitations purposes; it did not decide that every such claim requires the same favorable-termination showing required for a malicious-prosecution claim.

The court also relied on the Ninth Circuit’s later decision in Roberts v. City of Fairbanks. Roberts distinguished the favorable-termination element of malicious prosecution from the separate rule in Heck v. Humphrey, which prevents certain civil-rights damages claims unless the conviction has been invalidated. Heck recognizes invalidation when, among other things, a state tribunal authorized to make that decision declares the conviction invalid.

The court found it undisputed that Caldwell’s conviction had been invalidated in that manner. It therefore concluded that Caldwell did not have to plead that the criminal proceedings ended in a way establishing his innocence in order to proceed with his Section 1983 due process claim against Crenshaw.

Disposition

The court denied the defendants’ motion to dismiss Caldwell’s Section 1983 due process claim against Crenshaw. This ruling addressed only whether the claim could proceed at the pleading stage; it did not determine liability or the ultimate merits of the claim. Judge Donna Ryu entered the order on October 26, 2020.