Haughey v. County of Putnam
- Kenneth Karas
- 7:18-cv-02861
- U.S. District Court · Southern District of New York
- 3
In Haughey v. County of Putnam, Judge Karas accepted Haughey’s filing seeking to amend a proposed jury instruction about fabricated evidence.
The order affected Richard M. Haughey, as administrator of William Haughey’s estate, and the defendants in the pending case by accepting Haughey’s filing concerning a proposed jury instruction.
What happened
Richard M. Haughey, administrator of William Haughey’s estate, asked the court to accept a small change to a proposed jury instruction in Haughey v. County of Putnam. The proposed change concerned whether allegedly fabricated evidence was important enough to influence a jury.
Haughey argued that the evidence at issue—including statements and reports describing the fire as intentional and identifying Haughey as the person who started it—was material as a matter of law. He asked to revise the instruction so the jury would be told that this element of the evidence-fabrication claim was satisfied as a matter of law.
The court stated, “The Court will accept this filing.” Judge Kenneth M. Karas therefore accepted the filing, but the opinion does not state that the court issued the requested jury instruction or decided the underlying evidence-fabrication claim.
The detailed version
- Haughey v. County of Putnam · No. 7:18-cv-02861
- Kenneth Karas
- Sept. 11, 2023
Background
Richard M. Haughey, administrator of the estate of William Haughey, submitted a filing asking the court to allow a limited amendment to Haughey’s Requested Jury Instruction 15, concerning deprivation of a federal right through evidence fabrication. The filing stated that Haughey’s counsel had overlooked the requested instruction that the allegedly falsified evidence was material as a matter of law. Counsel also stated that the defendants would not be prejudiced because the final pretrial conference and trial had not yet occurred and the court had not issued jury instructions.
Requested amendment
The filing cited the elements of an evidence-fabrication claim, including that an investigating official fabricated information likely to influence a jury’s verdict, forwarded it to prosecutors, and thereby caused a deprivation of life, liberty, or property. Haughey argued that materiality asks whether a hypothetical jury would likely be influenced by the evidence, rather than whether the evidence actually affected a completed criminal trial.
Haughey identified the allegedly fabricated evidence as including statements that the Smalley’s bathroom fire was incendiary or arson; reports recording that conclusion; oral representations about the fire, electrical causes, the delay in securing the bathroom, and Anthony Porto, Jr.’s conduct; an incident report stating that eyewitnesses saw Haughey start the fire; and oral representations conveying that eyewitness information to other officials and prosecutors. Haughey argued that no reasonable jury could find this type of evidence unlikely to influence a jury’s decision if considered.
Ruling
The court stated: “The Court will accept this filing.” The opinion therefore records acceptance of the filing. It does not state that the court formally granted the requested jury instruction, issued the proposed instruction, or resolved the underlying evidence-fabrication claim. Judge Kenneth M. Karas’s order was an ancillary pretrial ruling about a proposed jury instruction.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.