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Wrongfully Convicted Members of “Beatrice Six” Entitled to Compensation Despite False Confessions; Eighth Circuit Reinstates Lawsuit

On July 18, 2014, the Nebraska Supreme Court unanimously affirmed the right of two members of the infamous “Beatrice Six” to receive up to $500,000 each in compensation despite the fact that they had both falsely confessed to a brutal murder.

In this convoluted case with many players, Helen Wilson, 68, was raped and killed in her Beatrice, Nebraska apartment in 1985. Initially a drifter by the name of Bruce Allen Smith was suspected of the crime, but the focus turned elsewhere when blood tests seemed to exclude him.

Four years later, James L. Dean, Ada Joann Taylor, Joseph E. White and three other suspects were arrested for the crime. Initially, they maintained their innocence. Dean took a polygraph test and was told the results “did not look good.”

A police psychologist, Dr. Wade Price, told Dean he had unconscious knowledge of the crime that would return to him in his dreams. During the same time, Dean was repeatedly shown videotapes, photographs and diagrams of the crime scene.

Dean then began to dream of Wilson’s murder and believed that Dr. Price had helped him remove a “subconscious block”; concerned about the polygraph results, he eventually confessed. Similarly, Taylor also received “help” from law enforcement to “remember” the crime. Shortly after her arrest she was told there was proof of her involvement in Wilson’s murder.

“I had no reason to believe the cops would lie to me,” she said.

Taylor was eventually able to “reconstruct” her supposed involvement in the crime after being supplied with facts related to the killing, including a videotape of the crime scene.

Both Taylor and Dean testified against White at his trial in exchange for shorter sentences. White was convicted of first-degree murder and sentenced to life. After pleading guilty to second-degree murder, Dean and Taylor spent about five and 19 years in prison, respectively. The other three members of the Beatrice Six – Thomas W. Winslow, Kathleen A. Gonzalez and Debra Shelden – also confessed, pleaded guilty and received prison terms.

In 2005, White filed a motion for DNA testing. The results of that test proved that Bruce Allen Smith’s blood was indeed found at the crime scene, but none of the Beatrice Six’s. Smith had died more than a decade earlier. All members of the Beatrice Six were exonerated; combined, they had served 77 years in prison. White died in 2011.

Dean and Taylor subsequently received pardons, then filed claims under the Nebraska Wrongful Conviction Act, which allows for payments up to $500,000 in compensation for wrongful imprisonment. However, according to Neb. Rev. § Stat. 29-4603, defendants who make “false statements” or commit perjury to bring about their conviction (or the conviction of another) are not entitled to receive compensation.

At trial, Gage County District Court Judge Daniel E. Bryan, Jr. found that at the time Dean and Taylor made their confessions they believed them to be true. Holding that their false confessions had been “persuaded” by law enforcement officials, and that both perjury and false statements require a “knowledge or intent” that one is not telling the truth, Judge Bryan awarded $300,000 to Dean and $500,000 to Taylor.

The state appealed both compensation awards while Dean cross-appealed, challenging his smaller award.

In a unanimous decision, the Nebraska Supreme Court upheld Dean and Taylor’s right to statutory damages, finding that they both “truly believed they were members of the Beatrice Six and involved in the murder of Wilson” due to police interrogation tactics.

“We can think of no logical reason why ... an innocent person who made a false but coerced confession” should not recover under the state’s compensation law, the Court wrote.

The Supreme Court affirmed Taylor’s $500,000 award but reversed the $300,000 award to Dean, because, as Dean had argued, the district court seemed to have based its decision to give him a lower amount on the fact that he served less time in prison than Taylor.

The Court said each compensation award must be made independently, not in comparison with each other, stating, “If both Dean and Taylor sustained actual damages in excess of the $500,000 cap, each would be entitled to recover that amount.”

Dean was represented by attorney Herbert J. Friedman and Taylor by Jeffry D. Patterson, Robert F. Bartle and Douglas Stratton. See: Dean v. State, 288 Neb. 530, 849 N.W.2d 138 (Neb. 2014).

The remaining members of the Beatrice Six are also pursuing a separate federal civil rights lawsuit against the Gage County Sheriff’s Office for fabricating evidence and coercing confessions in the case. The suit went to a jury trial in 2014 but resulted in a mistrial; the case was appealed to the Eighth Circuit, which on December 7, 2015 held the Beatrice Six should be allowed to argue that the officials who helped convict them had violated their rights.

The Court of Appeals reinstated the plaintiffs’ civil conspiracy claims and claims against Gage County, and upheld the district court’s order denying qualified immunity to the defendants. Based on the appellate ruling, a new trial will be scheduled on remand. See: Dean v. Cnty. of Gage, 807 F.3d 931 (8th Cir. 2015).

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