Background
Joaquin Ciria served thirty-two years in prison for the 1990 murder of Felix Bastarrica before being exonerated by the San Francisco District Attorney’s Innocence Commission. The Commission found that the star witness, George Varela, had falsely named Ciria as the shooter after police inspectors threatened him with an adult murder charge and offered him a story that would insulate him from liability. Ciria sued the inspectors under Section nineteen eighty-three, alleging fabrication of evidence and malicious prosecution.
The court’s reasoning
The panel held that under Ninth Circuit precedent, a reasonable jury could find the inspectors acted with deliberate indifference or reckless disregard for Ciria’s rights by using coercive tactics to fabricate evidence. The court found that threatening an eighteen-year-old with an adult murder charge and feeding him a specific story to avoid liability constituted fabrication. The court further determined that in nineteen ninety, it was clearly established that such conduct violated due process rights. Regarding the malicious prosecution claim, the court found that viewing the facts in the light most favorable to Ciria, it was not reasonably arguable that the officers had probable cause to arrest him without the coerced statement.
The dissent
He would therefore reverse the district court’s denial of qualified immunity to Defendants on both claims.
Miller
What it means going forward
The decision allows Ciria’s civil rights claims against the inspectors to proceed to trial, rejecting the argument that the officers were entitled to qualified immunity based on the state of the law in nineteen ninety.
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