Sufficiency of Evidence

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7^th Circuit Court of Appeals

Case Name: Nathson Fields v. City of Chicago, et al.,

Case No.: 17-3079; 17-3125; 18-1207

Officials: SYKES, Chief Judge, and RIPPLE and ROVNER, Circuit Judges.

Focus: Sufficiency of Evidence

These appeals stem from an action brought in 2010 by Nathson Fields, asserting claims under 42 U.S.C. § 1983 and state law against the City of Chicago and individuals including several Chicago police officers as well as two former Cook County prosecutors. The lawsuit alleged that the defendants violated Fields’s constitutional rights as well as state law in their actions in fabricating evidence and withholding exculpatory evidence in a criminal investigation that resulted in Fields’s conviction for murder. After a retrial that resulted in an acquittal, Fields filed this civil suit, and the jury entered an award in his favor on a number of grounds. Two individual defendants, Chicago Police Detectives David O’Callaghan and Joseph Murphy, and the City of Chicago, now appeal.

Our review is a narrow one. Jury verdicts are accorded great respect, and on review we consider whether the evidence presented to the jury was legally sufficient to support the verdict against the City. J.K.J., 960 F.3d at 378. In making that determination, we do not reweigh evidence, assess witness credibility, or otherwise usurp the role of the jury as factfinder, and we give the nonmovant the benefit of every inference. Id.; Ruiz-Cortez v. City of Chicago, 931 F.3d 592, 601 (7th Cir. 2019). “To the contrary, we must affirm unless there is ‘no legally sufficient evidentiary basis for a reasonable jury to find for the non-moving party.’” Id., quoting Woodward v. Corr. Med. Servs. of Ill., Inc., 368 F.3d 917, 926 (7th Cir. 2004).

Here, the district court properly recognized that “street files” were utilized by law enforcement officers and that a jury could find from the evidence introduced by Fields that there was a “systemic underproduction of exculpatory materials to prosecutors and defense counsel.” Corrected Op. at 7 n. 8. The City argues that it was not enough for Fields to produce evidence of ongoing use of street files in which investigative materials were withheld, but Fields must also demonstrate that the withheld evidence would have affected the outcome of the criminal trial. Although knowledge of the risk of constitutional violations is necessary for Monell liability, the City’s knowledge of that risk is unquestionable in this case. As the district court recognized, the City was aware as a result of prior litigation that the use of street files and the failure to ensure the production of the evidence within those files presented a constitutional problem. In Jones, 856 F.2d at 996, we recognized that the custom of the maintenance of street files was department-wide and of long standing, and that a jury could therefore conclude it was consciously approved at the highest policy-making level for decisions involving the police department. See also Palmer v. City of Chicago, 755 F.2d 560 (7th Cir. 1985). In fact, the City in Jones did not even contest that the use of such a practice presented a due process problem, although the City represented it had abandoned the practice. Id. at 995. The evidence presented in this case – that such street files were still being used and that exculpatory evidence from such files was still being withheld in criminal cases – allowed a jury to conclude that the City had failed to take the necessary steps to address that unconstitutional practice. Accordingly, the district court did not err in determining that there was a legally sufficient evidentiary basis for a reasonable jury to find for Fields on the issue of Monell liability.

Affirmed

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Derek A Hawkins is Associate Corporate Counsel, IP at Amazon.