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8th Circuit Upholds Dismissal of False Imprisonment Action

The Eighth Circuit Court of Appeals upheld a lower court’s grant of summary judgment to Defendants on a false imprisonment claim.

On January 2, 1983, James Buckley was murdered in St. Louis, Missouri. Ellen Maria Reasonover came forward as a witness the next day, but she was later arrested and charged with Buckley’s murder. “The evidence against Reasonover was based almost entirely on” her supposed confession.

In December 1983, Reasonover was convicted and sentenced to life imprisonment, with a 50-year minimum sentence. State courts affirmed her conviction. She filed a federal habeas corpus petition in 1996, and the district court vacated her conviction. After 16 years in prison, Reasonover was released.

In 2001, Reasonover and her daughter sued in federal court, alleging: malicious prosecution; false arrest; unreliable and fraudulent investigatory techniques; unreliable and fabricated evidence; suppression of exculpatory evidence; wrongful conviction and imprisonment; and other claims. The district court granted Defendants summary judgment on all claims and the Eighth Circuit affirmed. The court found that the prosecutor was entitled to absolute immunity and officers were entitled to qualified immunity. The court also rejected plaintiffs’ conspiracy, Monell liability, and familial association claims. See: Reasonover v. St. Louis, 447 F.3d 569 (8th Cir. 2006).

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Related legal case

Reasonover v. St. Louis