Suing a prosecutor that framed innocent men

…and the response that the prosecutors can’t be sued.

Back in 1978, two men, Curtis McGhee and Terry Harrington, were convicted of murdering security guard John Schweer, who had been killed while guarding a car lot. Their conviction rested almost completely on the testimony of one Kevin Hughes. Hughes was initially recruited to help the police solve the crime after he was arrested for riding in a stolen car. The police promised him that if he provided information to help solve the murder of Schweer, he would not be charged in connection with the murder, he would get his current charges dismissed, and be eligible for a $5,000 reward.

Hughes told the police many different stories: he first identified a suspect who he claimed admitted to him that he stole a Lincoln from the lot and shot the guard. Police advised him that no Lincoln was stolen. He next identified the killer as a man named Kelly. Police investigated this claim and discovered that Kelly had been demonstrably out of town that day. Hughes told the police the murder weapon had been a pistol, which was wrong, and then a 20-gauge shotgun, which was wrong, before arriving at the correct weapon, a 12-gauge shotgun. Finally the police began to tell Hughes specifically who they wanted him to identify, and he obligingly did so.

Working directly with the police and involved in the deception was the prosecutor, Assistant County Attorney Joseph Hrvol.

Hrvol also failed to mention at any time that the investigation had first centered on another man, Gates. Hrvol’s boss was running for re-election as county attorney for the first time, campaigning while the highly public crime remained unsolved. Gates was identified by three witnesses as being near the scene, with one witness able to say that he had a shotgun with him on the night of the crime. Eight reports were written by the police concerning Gates, and Gates failed a polygraph.

Nonetheless, the case proceded against McGhee and Harrington. Both of the accused men were convicted. They were given life sentences, exhausting their direct appeals possibilities. The exculpatory evidence surrounding the case, including the changing stories Hughes told and the existence of the suspect Gates was never disclosed to the defense.

And that’s where the story would have ended, but for the work of a prison employee, Anne Danaher. Danaher became friednly with Harrington and his family and began investigating the facts of the case. She uncovered the exculpatory evidence and the Iowa Supreme Court overturned the convictions based ont he Brady violation (the failure to provide exculpatory evidence to the defense).

The witness Hughes now admits he lied in an effort to secure the reward and dodge the car theft charge, and says that after several attempts on his part to concoct a workable story, detectives and prosecutors essentially told him what to say.

Harrington now sues the prosecutors, saying that they framed him. The prosecutors respond, in essence, “No, we didn’t, but even if we did, we’re entitled to absolute immunity for any actions we took as prosecutors.”

The case is now in front of the Supreme Court on this issue. At summary judgment below – in other words, a proceeding that takes every word the plaintiffs say as true, and every word the defendants say as a lie, the court determines if the plaintiffs can win.

The court below concluded that in a case of deliberate framing, absolute immunity did not apply, and that the prosecutors could be sued. The prosecutors now appeal this decision to the Supreme Court.

Weighing in on the side of the prosecutors: the United States. In other words, the Obama administration’s solicitor general will argue that the prosecutor’s absolute immunity applies in this case.

(The facts as I recite them above are taken from the plaintiff’s pleadings, which is correct to do as a matter of law – remember, this is summary judgment we’re talking about. Obviously the prosecutors argue they did so such thing.)

I think this is a surprising position for the administration to take. And a wrong one.

Open up the opportunity and everyone will accuse prosecutors of framing them.

It’s actually a prosecutor’s job to “frame” people, they’re supposed to build a case - which is usually several facts tied together by educated guesses, assumptions and some fiction that the prosecutor is supposed to believe could be true.

The line is crossed when this case building involves manufacturing evidence so that these guesses, assuptions and fiction become indisputable facts.

  1. I think the Supreme court should open the door.
  2. I think they should do so carefully so as to not fling it wide open.

The reason why the immunity should not apply: The precedent establishes prosecutors are immune from prosecution for their actions during the trial. In this case, the prosecutors were active in conducting the investigation and manufacturing evidence before the suspect was even indicted - long before the trial.

In mu opnion – and I’m aware there are issues that may be relevant which I don’t know – a governmental employee acting in accordance with law within the limits of his discretion should be exempt from prosecution or from personal suit. (Obviously, one can sue the agency in the Court of Claims or challenge the constitutionality or conformance to statute in Federal court.)

But whenever an official takes an action beyond discretion, or for purposes that are malo in se such as being bribed to prosecute someone, I believe he then becomes subject to prosecution or to lawsuit as an individual.
ETA: Pan’s post makes a very salient point. If anything cried out for a narrow decision, this is a case that does.

Didn’t we do this already in the Mike Nifong case?

That’s an odd usage of “frame.” In this context, it is generally understood to be the manufacture of evidence with the purpose of convicting an innocent person.

Is this the year for prosecutors to look like utter asses?

I don’t know if I’m surprised the administration is taking this position, but I too think it is the wrong one. Admittedly, that’s based on my gut and not on any deep understanding of law.

Is his immunity really absolute? I have personal immunity in the course of my job but only to the extent that I am acting within professional guidelines. If I do something illegal on the job my immunity is over and I face personal liability.

Nina Totenberg reports on the case.

Off course it’s an odd usage - that’s why its in quotations - to indicate that it’s not being used in the traditional sense.

What’s your point, then? This thread is about prosecutors framing someone in the traditional sense.

Isn’t it necessary to establish the prosecutors motive and frame of mind?

Situation 1:The prosecutors believed they had the right suspects (McGhee and Harrington), and cooked the evidence to put the bad guys in jail.

Situation 2: The prosecutors know for a fact that McGhee/Harrington are innocent, and cooked up evidence to send them to jail anyway.

Slightly different motive. Both are criminal actions, IMO, but still different shades of bad.

I have no idea. My point is that the kind of “framing” referred to in the OP is the kind that manufactures evidence in order to convict a person that the prosecutor knows to be innocent.

It shouldn’t be about whether the prosecutor believed the suspect was guilty or innocent, partly because that is very hard to prove, and partly because that need have no effect on the outcome of the case. It should be about whether the prosecutor suppressed evidence or fabricated evidence.

I was thinking it should matter for purposes of sentencing the former prosecutors and detectives. But you’re correct that those kind of cases get tough to prove in court, and most would probably be plea bargained.

No, it should not. Not even remotely. Not in a million effin years. I have a hard time even imaging why anyone, under any circumstances short of “putting away Hitler’s Darkspawned Demon Child by Satan’sd Eviller Mother-in-Law” would or could say that.

Why they did is irrelevant. Prosecutors, and police, are given wide latitude to maintain order and put away criminals. They are officers of the court, and mostly trusted to act honestly. We in turn require and demand much stricter standards of them than other citizens. There is a price for this.

These people deliberately manufactured evidence against a suspect. The suspect’s guilt or innocence, and their frame of mind in doing so, has no bearing on the issue. The appropriate and just penalty for this crime is nothing less than torture and a gruesome death both as the proper “reward” for subversion of justice, the gross and malicious abuse of a public office, and as a warning against all those who dare do the same. Fortunately for them, we as a society have opted for a more merciful justice system - the same which they twisted into an oppressive instrument.

No, their frame of mind is utterly irrelevant. Good intentions cannot excuse heinous actions such as these. Let them plead to God if they will, but before men they have no excuse.

The position of the prosecutors, and the administration in support of them is entirely wrong. Framing people with false information is an absolute wrong. Our position must be that prosecutors do not do that, and then we find remedies for the potential deluge of suits that might follow. Let justice be done though the heavens fall, in other words.

Otherwise, there’s no point in having a justice system. We have trials rather than summary judgments because we believe in the presumption of innocence and the necessity of due process. Saying that we uphold those things on the one hand, but allowing no redress against people in power who construct a falsehood in order to wrongly imprison someone on the other is an intolerable contradiction. We either do away with one or the other.

I am not going to assert that you are necessarily wrong, but I wish to clarify.

I think the difference is sorta like 1st Degree Murder and 2nd Degree. Both involve jailtime.

I do not think it excuses them from any punishment at all (like murder via self defence does let the accused “off the hook”).

Two questions:

Did the framed men receive any compensation for the time they spent in jail? In Canada, people wrongly convicted due to prosecutorial misconduct often receive compensation. David Milgaard received $10 million CAD, for example. If the two men received significant compensation for their wrongful conviction, that would obviate the need/benefit of suing the prosecutors, who should be punished otherwise.

Who exactly is arguing the government’s case? Is it the Obama administration, or the Justice Department? There’s a difference insofar as the DOJ is supposed to be arm’s length from the White House, and isn’t supposed to be directly an arm of administration policy. Saying “The Obama Administration” makes it sound like the Big O himself said “We have to fight this one” when it could as easily be the DOJ deciding that they need maximal discretion and immunization lest there be a chilling effect on prosecutors.

The Solicitor Generalargues the case. He is appointed by the President.

So she reports to Obama, not Eric Holder?