O'Connell v. Alejo

CourtCourt of Appeals for the Tenth Circuit
DecidedDecember 16, 2021
Docket20-1148
StatusUnpublished

This text of O'Connell v. Alejo (O'Connell v. Alejo) 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
O'Connell v. Alejo, (10th Cir. 2021).

Opinion

Appellate Case: 20-1148 Document: 010110620035 Date Filed: 12/16/2021 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT December 16, 2021 _________________________________________ Christopher M. Wolpert Clerk of Court KRYSTAL O’CONNELL,

Plaintiff - Appellee,

v. No. 20-1148 (D.C. No. 1:18-CV-01359-RBJ) MARCIA TUGGLE, former (D. Colo.) caseworker of the Alamosa Department of Human Services,

Defendant - Appellant,

and

HARRY ALEJO, former Alamosa County Sheriff’s Office Sergeant; BOARD OF COUNTY COMMISSIONERS OF THE COUNTY OF ALAMOSA, COLORADO; ROBERT JACKSON, Sheriff of Alamosa County, Colorado,

Defendants. __________________________________________

ORDER AND JUDGMENT * __________________________________________

Before BACHARACH, BRISCOE, and EID, Circuit Judges. ___________________________________________

* This order and judgment does not constitute binding precedent except under the doctrines of law of the case, res judicata, and collateral estoppel. But the order and judgment may be cited for its persuasive value if otherwise appropriate. Fed. R. App. P. 32.1(a); 10th Cir. R. 32.1(A). Appellate Case: 20-1148 Document: 010110620035 Date Filed: 12/16/2021 Page: 2

This appeal stems from notes that a social worker made after

interviewing a woman suspected of child abuse. The social worker (Ms.

Marcia Tuggle) wrote that the woman (Ms. Krystal O’Connell) had

confessed. Ms. O’Connell denied confessing and presented evidence that

Ms. Tuggle had lied in her notes about the alleged confession. Did the law

clearly establish Ms. O’Connell’s constitutional protection from the social

worker’s fabrication of a confession in a criminal investigation? The

district court answered “yes,” as we do.

1. Ms. Tuggle allegedly fabricated a confession by Ms. O’Connell.

In 2003, Ms. O’Connell left her young son, Kyran, in the care of Mr.

Patrick Ramirez. Doctors soon diagnosed Kyran with serious brain injuries,

and he died about two months later.

The police opened an investigation. Sergeant Harry Alejo

interviewed Mr. Ramirez, who told the police that he was carrying Kyran

when he fell.

Ms. Tuggle also investigated. She interviewed Mr. Ramirez, who

repeated what he had told Sergeant Alejo. Two days later, Ms. Tuggle and

Sergeant Alejo attended doctors’ meetings and interviewed witnesses.

Sergeant Alejo first interviewed Ms. O’Connell without anyone else

in the room. Later the same day, Sergeant Alejo and Ms. Tuggle conducted

a joint interview of Ms. O’Connell. According to Ms. O’Connell, Sergeant

Alejo hurled accusations while Ms. Tuggle watched. Ms. Tuggle noted the

2 Appellate Case: 20-1148 Document: 010110620035 Date Filed: 12/16/2021 Page: 3

responses, stating that Ms. O’Connell had admitted shaking Kyran and

slamming him on the bed. Ms. O’Connell denied saying this and presented

evidence that Ms. Tuggle had fabricated the confession.

Ms. O’Connell was ultimately convicted of child abuse resulting in

Kyran’s death. But in 2017, Ms. O’Connell’s conviction was overturned.

She then sued Ms. Tuggle for a denial of due process. The district court

denied Ms. Tuggle’s motion for summary judgment, rejecting her argument

for qualified immunity.

2. We have jurisdiction.

Ms. O’Connell moves to dismiss the appeal for lack of jurisdiction.

We deny this motion.

Appellate jurisdiction exists when a district court denies qualified

immunity based on an issue of law. Mitchell v. Forsyth, 472 U.S. 511, 530

(1985). The appeal turns on an issue of law because Ms. Tuggle concedes

“the most favorable view of the facts to [Ms.] O’Connell.” Appellant’s

Opening Br. at 14. Under this view, we follow the district court in

crediting allegations that Ms. Tuggle had participated in an investigation

into Ms. O’Connell, had participated in an interview with Sergeant Alejo,

and had taken notes regarding the investigation. Ms. Tuggle has also

conceded the use of her notes to deprive Ms. O’Connell of her liberty. So

3 Appellate Case: 20-1148 Document: 010110620035 Date Filed: 12/16/2021 Page: 4

Ms. Tuggle has raised a purely legal question, triggering appellate

jurisdiction. 1

3. To determine whether the constitutional right was clearly established, we conduct de novo review.

In exercising this jurisdiction, we conduct de novo review. Gutierrez

v. Cobos, 841 F.3d 895, 900 (10th Cir. 2016). For this review, we apply the

same standard that governed in district court, which allows summary

judgment only if there is no genuine dispute of material fact and the

movant is entitled to judgment as a matter of law. Id. In determining the

existence of a dispute of material fact, we must view the evidence in the

light most favorable to the nonmoving party, Ms. O’Connell. Id.

Ms. Tuggle moved for summary judgment based on qualified

immunity. So when viewing the evidence favorably to Ms. O’Connell, the

district court must deny Ms. Tuggle’s motion for summary judgment if

 a factfinder could reasonably find facts showing the violation of a constitutional right and

 the right was clearly established when Ms. Tuggle engaged in misconduct.

Id. at 900–01.

Ms. Tuggle does not contest the existence of facts showing the

violation of a constitutional right. She instead argues that the underlying

1 Ms. O’Connell also argues that we lack jurisdiction because the assertion of qualified immunity is frivolous. Though we reject Ms. Tuggle’s assertion of qualified immunity, her arguments are not frivolous. 4 Appellate Case: 20-1148 Document: 010110620035 Date Filed: 12/16/2021 Page: 5

right had not been clearly established. A right is clearly established only if

a reasonable official would understand that the challenged conduct violates

that right. Perry v. Durborow, 892 F.3d 1116, 1122–23 (10th Cir. 2018).

Generally, a right is clear when it is apparent from controlling precedent or

the clear weight of persuasive authorities from other circuits. Id. at 1123.

But even without precedential or persuasive authorities, a right can be

clearly established when it is obvious. See Taylor v. Riojas, 141 S. Ct. 52,

53–54 (2020) (per curiam). “After all, some things are so obviously

unlawful that they don’t require detailed explanation and sometimes the

most obviously unlawful things happen so rarely that a case on point is

itself an unusual thing.” Browder v. City of Albuquerque, 787 F.3d 1076,

1082 (10th Cir. 2015) (Gorsuch, J.).

4. Ms. O’Connell had a clearly established constitutional protection against the fabrication of evidence in a criminal investigation.

To decide whether Ms. Tuggle violated a clearly established

constitutional right, we must determine the universe of facts that we can

consider. Given the denial of summary judgment, we credit Ms.

O’Connell’s allegations as true even if our own review of the record might

suggest otherwise. Cox v. Glanz, 800 F.3d 1231, 1242 (10th Cir. 2015).

The district court credited five of Ms. O’Connell’s allegations

bearing on qualified immunity:

1. Ms. Tuggle had participated in the investigation of Ms. O’Connell and contributed to the deprivation of her liberty.

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