42 USC § 1983; Violation of the Fourteenth Amendment right to due process; Violations of Brady v. Maryland; Strickler v. Greene; Moldowan v. City of Warren; Galloway v. United States; Giglio v. United States; Evidence fabrication; Gregory v. City of Louisville; Stemler v. City of Florence; Conspiracy to withhold & fabricate evidence; Robertson v. Lucas; Revis v. Meldrum; Doherty v. American Motors; The “intracorporate conspiracy doctrine”; Johnson v. Hills & Dales Gen. Hosp.; Hull v. Cuyahoga Valley Joint Vocational Sch. Dist. Bd. of Educ.; DiLuzio v. Village of Yorkville; Grider v. City of Auburn (11th Cir.); Rehberg v. Paulk (11th Cir.); Fourth Amendment right to be free from malicious prosecution; Mills v. Barnard; Sykes v. Anderson; Higazy v. Templeton; King v. Harwood; Qualified immunity; Pearson v. Callahan; Harlow v. Fitzgerald; Saunders-El v. Rohde (7th Cir.); Hope v. Pelzer; United States v. Lanier; Barbee v. Warden, MD Penitentiary (4th Cir.); Municipal liability; Monell v. Department of Soc. Servs.; D’Ambrosio v. Marino; Burgess v. Fischer; Garner v. Memphis Police Dep’t; Failure to train; Ciminillo v. Streicher; City of Canton v. Harris; Deliberate indifference; Board of Cnty. Comm’rs v. Brown; Campbell v. City of Springboro

In an issue of first impression, the court held that “the intracorporate conspiracy doctrine applies in § 1983 cases to bar conspiracy claims where two or more employees of the same entity are alleged to have been acting within the scope of their employment when they allegedly conspired” to deprive a plaintiff of his or her rights. Plaintiffs were wrongfully imprisoned for decades based on eyewitness testimony that was eventually recanted. The district court granted defendant-Stoiker, a police detective on the case, summary judgment on plaintiffs’ § 1983 claim alleging that he violated Brady by withholding exculpatory evidence. It determined that there was insufficient evidence to allow a jury to find that he withheld any evidence. But the court disagreed, finding that record evidence indicated he was involved where he signed the police report regarding the witness’s (V) coerced identification. A jury could believe that he was present and thus, knew the true facts behind the identification, and “‘nondisclosure of evidence affecting credibility falls within [Brady’s disclosure] rule.’” Further, the coerced identification formed the core of the prosecution’s case. As for fabrication of evidence, there was evidence Stoiker was in the room when the identification was coerced; thus, “a reasonable jury could infer that Stoiker either drafted, or assisted [another detective] in drafting, the false statement.” A reasonable jury could also find that Stoiker and the other detective “planned to draft a false statement and coerce [V] into signing that statement and that they committed an overt act in furtherance of that plan[,]” thus supporting the claim of conspiracy to withhold or fabricate evidence. However, because they both had the same employer, the court for the first time considered the applicability of the intracorporate conspiracy doctrine to § 1983 cases and held that it applied. The exception for defendants that were alleged to have been acting outside the scope of their employment could not apply here because plaintiffs alleged that the defendants were acting within the scope of their employment. The court affirmed summary judgment to Stoiker on the conspiracy claims but reversed on the malicious prosecution, withholding exculpatory evidence, and fabricating evidence claims. Further, it held that plaintiffs’ Monell claims against defendant-Cleveland were improperly dismissed where there were “genuine issues of material fact both as to whether Cleveland had an official policy of permitting the withholding of exculpatory witness statements from prosecutors and as to whether Cleveland had a policy of failing to train its officers in” their disclosure obligations.