Background
Plaintiffs Aaron Nguyen and his parents appealed a district court’s grant of summary judgment in favor of the City of Garden Grove and three police officers. The case arose from Aaron’s now-reversed criminal conviction and incarceration, involving claims under Section nineteen eighty-three of the United States Code.
The court’s reasoning
The court reviewed the grant of summary judgment de novo. It determined that the Plaintiffs failed to show the evidence was withheld for their Brady claim because the City turned over all material and the defendant was aware of the facts. However, the court found a genuine dispute of material fact regarding a deliberate fabrication claim against Detective Lord. The court noted that Detective Lord’s report contained statements contradicting video and written transcripts, which a reasonable jury could find to be significant mischaracterizations. The court held that harsh interrogation tactics alone did not meet the standard for deliberate fabrication. Because the underlying due process claim was reversed, the court also reversed the dismissal of the parents’ due process claims, supervisory liability claims, and Monell claims, remanding them to the district court.
The dissent
I respectfully dissent from the majority disposition on the deliberate fabrication of evidence claim for two reasons. The first is that Detective Lord’s actions in this case did not rise to the level of deliberate fabrication of evidence. The second is that Detective Lord is entitled to qualified immunity for his actions.
Rawlinson
What it means going forward
The case is remanded to the district court to determine whether Detective Reynolds or Sergeant Martin bear supervisory liability for Detective Lord’s allegedly fabricated report and to consider the remaining due process and Monell claims.