Sufficiency of Evidence

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7^th Circuit Court of Appeals

Case Name: Christopher Coleman v. City of Peoria, Illinois, et al.

Case No.: 18-1742

Officials: RIPPLE, MANION, and BRENNAN, Circuit Judges.

Focus: Sufficiency of Evidence

Almost twenty‐five years ago, a jury convicted Christopher Coleman of armed robbery, home invasion, residential burglary, and aggravated sexual assault. Three witnesses linked Coleman to the crimes, and their identifications were the key evidence leading to his conviction. The court sentenced Coleman to sixty years’ imprisonment.  Fifteen years later, a group of men came forward claiming they were responsible for the crimes. Based on this new evidence, the Illinois Supreme Court ultimately vacated Coleman’s convictions and remanded for retrial. People v. Coleman, 996 N.E.2d 617 (Ill. 2013). Rather than retry the case, the prosecution decided to drop it. After nineteen years behind bars, Coleman was released in 2013, and a later judicial order certified his innocence.

Coleman has now sued the City of Peoria and four police officers—Patrick Rabe, Terry Pyatt, Timothy Anderson, and Michael Ford—accusing them of constitutional violations and state torts. Specifically, Coleman contends defendants elicited a false statement from an alleged accomplice through coercive interrogation techniques, employed improper and unduly suggestive identification procedures, and suppressed impeachment evidence. After three years of civil litigation, the district court granted defendants summary judgment on Coleman’s federal claims and state law malicious prosecution claim, and it relinquished supplemental jurisdiction over his remaining state law claims.

We agree with the district court’s summary judgment decision and affirm. Coleman failed to present evidence supporting a reasonable inference that defendants knowingly fabricated false evidence, caused unreliable eyewitness identifications to taint his criminal trial, withheld material evidence, or arrested him without probable cause.

Affirmed

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Derek A Hawkins is trademark corporate counsel for Harley-Davidson. Hawkins oversees the prosecution and maintenance of the Harley-Davidson’s international trademark portfolio in emerging markets.