Murphy v. City of Tulsa

950 F.3d 641
CourtCourt of Appeals for the Tenth Circuit
DecidedDecember 16, 2019
Docket18-5097
StatusPublished
Cited by30 cases

This text of 950 F.3d 641 (Murphy v. City of Tulsa) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Murphy v. City of Tulsa, 950 F.3d 641 (10th Cir. 2019).

Opinion

FILED United States Court of Appeals PUBLISH Tenth Circuit

December 16, 2019 UNITED STATES COURT OF APPEALS Elisabeth A. Shumaker FOR THE TENTH CIRCUIT Clerk of Court ____________________________________

MICHELLE DAWN MURPHY,

Plaintiff - Appellant,

v. No. 18-5097

THE CITY OF TULSA,

Defendant - Appellee. _________________________________

Appeal from the United States District Court for the Northern District of Oklahoma (D.C. No. 15-CV-528-GFK-FHM) _________________________________

John J. Carwile (Tara D. Zickefoose with him on the briefs), Baum Glass Jayne & Carwile PLLC, Tulsa, Oklahoma, on behalf of the Plaintiff- Appellant.

T. Michelle McGrew (Kristina L. Gray with her on the briefs), Tulsa, Oklahoma, on behalf of the Defendant-Appellee.

_________________________________

Before BACHARACH, McHUGH, and EID, Circuit Judges. _________________________________

BACHARACH, Circuit Judge. ________________________________

This appeal grew out of the Tulsa Police Department’s investigation

into the murder of an infant. The police suspected the infant’s mother, Ms. Michelle Murphy. Ms. Murphy ultimately confessed, but she later recanted

and sued the City of Tulsa under 42 U.S.C. § 1983. The district court

granted summary judgment to the City, concluding that Ms. Murphy had

not presented evidence that would trigger municipal liability. We affirm.

I. Ms. Murphy is convicted of murder after confessing in an allegedly coercive interrogation.

Roughly 25 years ago, Ms. Murphy had two small children: an infant

son and a little girl. The infant son was killed, and the police suspected

Ms. Murphy. She ultimately confessed after allegedly being threatened that

she’d never be able to see her little girl again.

Ms. Murphy’s confession led to her conviction for murder. After she

had served roughly 20 years in prison, her conviction was vacated and the

case was dismissed with prejudice.

II. Ms. Murphy sues the City, which obtains summary judgment based on a failure to prove a basis for municipal liability.

Ms. Murphy sued the City of Tulsa under 42 U.S.C. § 1983, claiming

that

• a police officer had violated the Constitution by coercing her confession and

• the City of Tulsa had incurred liability for that constitutional violation.

The district court concluded that the City could not incur liability because

the constitutional violation had not resulted from an unlawful policy or

2 custom. 1 Given this conclusion, the district court granted summary

judgment to the City.

III. Our review is de novo.

We engage in de novo review, “drawing all reasonable inferences and

resolving all factual disputes in favor of [Ms. Murphy].” Yousuf v.

Cohlmia, 741 F.3d 31, 37 (10th Cir. 2014). With these favorable

inferences, we consider whether the City of Tulsa has shown the lack of a

genuine dispute of material fact and the City’s entitlement to judgment as a

matter of law. Fed. R. Civ. P. 56(a).

IV. No municipal policy or custom authorized police officers to threaten citizens during interrogations.

Municipalities can incur liability for their employees’ constitutional

torts only if those torts resulted from a municipal policy or custom. Hinton

v. City of Elwood, 997 F.2d 774, 782 (10th Cir. 1993). Five potential

sources exist for a municipal policy or custom:

1. a “formal regulation or policy statement,”

2. an informal custom amounting to a “widespread practice that, although not authorized by a written law or express municipal policy, is so permanent and well-settled as to constitute a custom or usage with the force of law,”

3. the decision of a municipal employee with final policymaking authority,

1 The district court also concluded that a genuine issue of material fact existed on the constitutionality of the interrogation. We need not address that conclusion. 3 4. a policymaker’s ratification of a subordinate employee’s action, and

5. a failure to train or supervise employees.

Bryson v. City of Oklahoma City, 627 F.3d 784, 788 (10th Cir. 2010)

(internal quotation marks omitted).

Ms. Murphy relies on each potential source of municipal liability. In

our view, however, Ms. Murphy failed to present evidence supporting

municipal liability under any of the five sources. 2

A. No formal regulation or policy statement authorized police officers to make threats. Official policies can exist through municipalities’ “formal rules or

understandings.” Pembaur v. City of Cincinnati, 475 U.S. 469, 480–81

(1986). These formal rules or understandings are “often but not always

committed to writing” and “establish fixed plans of action to be followed

under similar circumstances consistently and over time.” Id.

Ms. Murphy argues that a formal rule authorized officers to use

threats, pointing to

• a former police chief’s testimony that police officers could decide for themselves what kinds of threats to use during interrogations and

2 Because Ms. Murphy has not established a municipal policy or custom, we need not decide whether a “direct causal link [exists] between the policy or custom and the injury alleged.” Bryson v. City of Oklahoma City, 627 F.3d 784, 788 (10th Cir. 2010) (quoting Hinton v. City of Elwood, 997 F.2d 774, 782 (10th Cir. 1993)). 4 • the City’s alleged abandonment of a prohibition against threats in interrogations.

But Ms. Murphy failed to properly support these arguments in district

court.

1. Ms. Murphy did not properly present the district court with the former police chief’s testimony about the permissibility of threats.

An official policy exists only if it came from a final policymaker.

Brammer-Hoelter v. Twin Peaks Charter Acad., 602 F.3d 1175, 1189 (10th

Cir. 2010). The parties agree that the only final policymaker here is the

former police chief, and Ms. Murphy relies on his testimony. But Ms.

Murphy didn’t properly present the district court with the pertinent part of

this testimony. Ms. Murphy’s error wasn’t merely technical. The district

court might have discovered the pertinent part of the testimony only by

trudging without guidance through 1540 pages of exhibits.

Ms. Murphy relies here on this excerpt from the former police chief’s

testimony:

Q. [The sergeant] further testified that the interrogator had the full authority of the Tulsa Police Department to decide what touching of the suspect would occur. Do you agree with that testimony?

A. I believe there were guidelines about no sexual touching. I mean, that would be a violation of law. But touching a suspect is not specifically prohibited.

Q. [The sergeant] further testified that an interrogator had the full authority of the Tulsa Police Department to decide

5 what kind of threats to make. Do you agree with that testimony?

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