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Chatman v. City of Chicago

United States District Court, N.D. Illinois, Eastern Division

September 12, 2016

CARL CHATMAN, Plaintiff,


          John Z. Lee United States District Judge.

         Plaintiff Carl Chatman filed a 42 U.S.C. § 1983 suit against the City of Chicago and various individual defendants alleging constitutional violations arising from his false conviction. Defendants Millicent Willis, Tisa Morris, Lori Lightfoot, and Karen Wojtczak, who worked for the Office of Professional Standards (OPS Defendants), filed a motion to dismiss [343]. For the reasons discussed below, the Court grants the motion in part and dismisses Counts IV, V, VI, and VII against the OPS Defendants.

         Factual and Procedural Background[1]

         Plaintiff Carl Chatman was convicted of rape even though he was innocent. Following his arrest, Chatman was interrogated by Chicago Police Detective Kriston Kato who used force to coerce Chatman into confessing. See 2d Am. Compl. ¶¶ 54-56, ECF No. 324. Two days later, a detective submitted an anonymous memorandum describing Kato's misconduct and the resulting false confession. See Id. ¶¶ 120-21. The memo was sent through inter-departmental mail to Millicent Willis, who at the time was the acting Chief Administrator for the Office of Professional Standards (OPS)-an agency in charge of investigating police misconduct. See Id. ¶ 122.

         Initially, the memo did not prompt any form of investigation from OPS. See Id. ¶ 123. Based on the false confession, Chatman was convicted of rape. While his case was on direct appeal, the anonymous detective once again submitted the memo. This time, OPS began an investigation into the alleged misconduct. See Id. ¶¶ 128-33. The OPS investigation, which included interviewing Chatman himself, was closed a few months later when the anonymous memo was determined to be unfounded. See Id. ¶ 133. The memo was never turned over to the prosecutors or Chatman's criminal attorney. See Id. ¶ 134.

         After spending eleven years in prison, Chatman was exonerated by the State of Illinois. See Id. ¶¶ 1, 6. He then filed this civil rights lawsuit against various defendants asserting constitutional violations based on the investigation and prosecution of his criminal case. In his Second Amended Complaint, Chatman included claims against Millicent Willis, Tisa Morris, Lori Lightfoot, and Karen Wojtczak-who were all employees of OPS-based on the failure to disclose the anonymous memo to the prosecution or Chatman's defense counsel.

         Legal Standard

         To survive a motion to dismiss pursuant to Rule 12(b)(6), a complaint must “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The Court must accept “all well-pleaded factual allegations as true and view them in the light most favorable to the plaintiff.” Lavalais v. Vill. of Melrose Park, 734 F.3d 629, 632 (7th Cir. 2013) (citing Luevano v. Wal-Mart Stores, Inc., 722 F.3d 1014, 1027 (7th Cir. 2013)). Mere legal conclusions, however, “are insufficient to survive a Rule 12(b)(6) motion.” McReynolds v. Merrill Lynch & Co., Inc., 694 F.3d 873, 885 (7th Cir. 2012) (citing Iqbal, 556 U.S. at 678).


         Chatman's core claim against the OPS Defendants stems from their failure to turn over the anonymous memo to the prosecution or Chatman's attorney during his criminal proceeding. See Brady v. Maryland, 373 U.S. 83, 87 (1963). The OPS Defendants contend they do not have a duty to disclose under Brady because they are not part of the prosecution team. Alternatively, they argue that, even if such a duty were to exist, they are entitled to qualified immunity because, at the time, there was no clearly established law creating such a duty.

         “The qualified immunity defense requires us to consider only two limited questions at this stage: first, whether plaintiff has alleged a violation of his constitutional rights, and second, whether the violation was clearly established in the law at the time of the defendant's conduct.” Armstrong v. Daily, 786 F.3d 529, 537 (7th Cir. 2015). The Court has discretion to decide a case under the second step without resolving whether the purported duty exists. See Dibble v. Quinn, 793 F.3d 803, 807 (7th Cir. 2015) (citing Pearson v. Callahan, 555 U.S. 223, 227 (2009)). The Court takes that approach here.

         The OPS Defendants argue, that even if they had a duty to disclose exculpatory material, such an extension of Brady was not clearly established at the time of Chatman's criminal proceedings. “To determine whether a right is clearly established we look to controlling precedent from both the Supreme Court and this circuit, and if there is no such precedent we cast a wider net and examine all relevant case law to determine whether there was such a clear trend in the case law that we can say with fair assurance that the recognition of the right by a controlling precedent was merely a question of time.” Abbott v. Sangamon Cty., Ill., 705 F.3d 706, 731 (7th Cir. 2013). Although the right must be clearly established in a particularized sense, there need not be a case directly on point. See Id. “[O]fficials can still be on notice that their conduct violates established law even in novel factual circumstances.” Hope v. Pelzer, 536 U.S. 730, 741 (2002).

         Initially, only the members of the prosecution bore the obligation to disclose material, exculpatory evidence to defense counsel. See Brady, 373 U.S. at 87. Subsequently, Brady was extended so that the prosecutor's duty to disclose reached evidence in the hands of police officers, even if the information was not known to the prosecutor. See Kyles v. Whitley, 514 U.S. 419, 437 (1995). Although the rule was articulated in terms of a duty by the prosecutor to learn of information held by the police, it has also been understood to establish an independent duty on the part of police officers to disclose such information. See Steidl v. Fermon, 494 F.3d 623, 630-33 (7th Cir. 2007) (holding that the duty of police officers to disclose exculpatory information-which is enforceable under § 1983-has been clearly established since Kyles).

         That said, neither the Seventh Circuit nor the Supreme Court has addressed whether governmental agencies that are in charge of investigating the police officers themselves-as opposed to the criminal defendant-are also subject to the duty to disclose under Brady. The closest the Seventh ...

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