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US Court of Appeals Dismisses Freed Prisoner's §1983 Claim

US Court of Appeals Dismisses Freed Prisoner's §1983 Claim

The United States Court of Appeals for the Seventh Circuit affirmed in December 2011 the district court’s dismissal of an Illinois prisoner’s civil rights claim against three police officers and three prosecutors. Plaintiff/Appellant Angel Rodriguez was convicted of murder, but the state’s appellate court reversed after concluding that the evidence was insufficient. Rodriguez sued, claiming the police officers unduly influenced a witness into identifying him as the killer. District court conferred judgment for one officer and let the other, and the City of Chicago, go to trial. Rodriguez lost.

Four years later he refiled, amending three prosecutors as defendants. District court dismissed the original defendants on grounds of claim preclusion (res judicata) and dismissed on the prosecutors on grounds of limitations. The court also mentioned lack of subject matter jurisdiction and immunity for the prosecutors.

In appeal, Rodriguez contended the district judge erred with respect to both the preclusion and the statute of limitations because of a state statute enacted in 2008 entitling a wrongly convicted prisoner a “certificate of innocence.” The certificate, Rodriguez contended, created a new claim, restarting the limitation timer and overruling the rules of issue and claim preclusion.

The court of appeals disagreed with Rodriguez. The preclusive effect of a federal court’s judgment on a case disputing federal law rests entirely on federal law and is immune to state constructs. The innocence statute expressly stated it “shall not have a res judicial effect on any… proceedings” other than a claim against the state. The statute provides for awardees of the certificate to have opportunity to seek redress in the state claims court, but it is only for claims against the state – not its employees. Prosecutors are not respondent to the reaches of the innocence statute.

Rodriguez, the court of appeals held, misapplied case law and inaccurately developed a string of logic that led him to the erroneous conclusion that his limitations timer restarted in 2009, when in actuality it started in 2000, at which time his claim accrued with his original reversal.

The court of appeals left open the avenue of litigation against the prosecutors in an individual capacity through federal court with its modified judgment of dismissed without prejudice. See: Rodriguez v. Cook County, Ill., 664 F.3d 627 (7th Cir. 2011).

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Related legal case

Rodriguez v. Cook County, Ill.