Carnes v. Blehm – Do It For The Caselaw

Holding: The Eighth Circuit affirmed the district court's denial of summary judgment, holding that genuine issues of material fact exist regarding the defendants' qualified immunity and prosecutorial immunity.
Standard: Reckless investigation standard; clearly established law
Vote: Panel Decision
Practical effect: The ruling allows Carnes's civil rights claims to proceed to trial, permitting a jury to determine if the law enforcement officers and prosecutor acted with reckless disregard for his constitutional rights.

The Eighth Circuit affirmed the denial of summary judgment against police detectives and a prosecutor in a civil rights suit alleging a reckless investigation and evidence suppression. The court held that genuine disputes of material fact exist regarding whether the defendants violated clearly established law by ignoring exculpatory evidence and coercing witnesses.

Background

Keith Carnes was convicted of murder in 2005 based on witness testimony that contradicted physical evidence. After serving eighteen years, the Missouri Supreme Court granted habeas relief in 2022 due to a Brady violation involving undisclosed evidence. Carnes subsequently filed a Section one thousand nine hundred eighty-three lawsuit against police detectives and a prosecutor, alleging they fabricated evidence, suppressed exculpatory information, and conducted a reckless investigation.

The court’s reasoning

The court reviewed the denial of summary judgment de novo, viewing evidence in the light most favorable to the plaintiff. For the detectives, the court found that ignoring the lack of physical evidence at the crime scene, failing to follow up on alibis for alternative suspects, and the alleged coercion of an intoxicated witness could constitute a reckless investigation that shocks the conscience. Regarding the prosecutor, the court determined that allegations of evidence suppression and fabrication before probable cause existed created a genuine dispute of material fact, stripping her of absolute prosecutorial immunity and qualified immunity.

What it means going forward

The ruling allows Carnes’s civil rights claims to proceed to trial, permitting a jury to determine if the law enforcement officers and prosecutor acted with reckless disregard for his constitutional rights.