SWAINSON v. CITY OF PHILADELPHIA

CourtDistrict Court, E.D. Pennsylvania
DecidedJuly 2, 2025
Docket2:22-cv-02163
StatusUnknown

This text of SWAINSON v. CITY OF PHILADELPHIA (SWAINSON v. CITY OF PHILADELPHIA) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SWAINSON v. CITY OF PHILADELPHIA, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

ANDREW SWAINSON : CIVIL ACTION : v. : : CITY OF PHILADELPHIA, ET AL. : NO. 22-2163

MEMORANDUM

Padova, J. July 2, 2025

Plaintiff Andrew Swainson brought this action pursuant to 42 U.S.C. § 1983 and state common law against the City of Philadelphia and certain police officers arising from his wrongful conviction for the 1988 murder of Stanley Opher. Plaintiff was convicted in 1989 and imprisoned for more than 30 years. The City and Defendant Detectives Joseph Fischer and James Alexander (the “Moving Defendants”) have brought a Motion in Limine to preclude Mr. Swainson from introducing at trial the testimony and Expert Report of Michael K. Lynch, Mr. Swainson’s expert on police practices. For the reasons that follow, the Motion is denied. I. BACKGROUND1 Mr. Swainson contends that he was wrongfully convicted of the murder of Mr. Opher because police officers (1) falsified evidence that he had fled to Jamaica after Mr. Opher’s murder to avoid prosecution; (2) falsified evidence that he had been identified as the person who shot Mr. Opher by an eyewitness to the crime; (3) concealed evidence that could have been used by his trial counsel to impeach prosecution witnesses; (4) concealed evidence of alternate perpetrators; and (5) concealed evidence that would have supported an alternate theory of the

1 See our Memorandum granting in part and denying in part the Motions for Summary Judgment filed by the City of Philadelphia, and Detectives Joseph Fischer, James Alexander, and Manuel Santiago for an extensive recitation of the factual background of the investigation conducted by the police, as well as of Mr. Swainson’s prosecution and post-conviction litigation. reason for Mr. Opher’s murder. One of Mr. Swainson’s claims in this case is a municipal liability claim against the City of Philadelphia pursuant to 42 U.S.C. § 1983, which asserts that the City is liable for his wrongful conviction and imprisonment because the Defendant Detectives acted in accordance with City policies and customs when they violated his constitutional rights and because the City failed to properly supervise and discipline the police officers who violated his

constitutional rights. A municipality “may not be sued under § 1983 for an injury inflicted solely by its employees or agents.” Monell v Dep’t of Soc. Servs., 436 U.S. 658, 694 (1978). Rather, to prove a § 1983 claim against a municipality, a plaintiff must demonstrate that his constitutional deprivations were caused by an official policy or custom of the municipality or a failure by the municipality to train, discipline, or supervise its employees. Id.; see also City of Canton v. Harris, 489 U.S. 378, 388 (1989); Bd. of Cnty. Comm’rs of Bryan Cnty. v. Brown, 520 U.S. 397, 403-04 (1997); Forrest v. Parry, 930 F.3d 93, 105 (3d Cir. 2019) (citing Estate of Roman v. City of Newark, 914 F.3d 789, 798-99 (3d Cir. 2019)). Mr. Swainson has produced an Expert Report authored by Michael K. Lynch in support

of his municipal liability claim against the City. (See Lynch Rpt. (Docket No. 91).) Mr. Swainson also plans to call Mr. Lynch to testify at trial. Mr. Lynch has 32 years of experience in law enforcement. (Lynch Rpt. Ex. B at 1.) He was employed by the Camden City Police Department from 1994 until 2013, serving as an officer/detective (1994-1997), sergeant (1997- 2000), command officer (2000-2008), and deputy chief of police (2008-2013). (Id. at 2.) Since 2013, Mr. Lynch has been employed by the Camden County Police Department as assistant chief of police (2013-2014), senior policy advisor (2015-2023), and chief of staff (since 2023). (Id. at 1.) As chief of staff, Mr. Lynch assists the chief of police in connection with accounting, human resources, procurement, administrative support services, and police records. (Id.) In his previous position, as senior policy advisor, he advised the chief of police on day-to-day operations, investigative practices, and operational protocols. (Id.) Mr. Lynch reviewed the following documents, among others, in the preparation of his Report in this case: deposition transcripts of Detective Santiago, Detective Fischer, and the Assistant District Attorney who prosecuted Mr. Swainson, Judith Rubino; the Philadelphia

Police Department’s (“PPD”) homicide file for Stanley Opher; newspaper articles about police misconduct and corruption in Philadelphia published by the Philadelphia Inquirer, the New York Times, and the Washington Post; pleadings, opinions, and consent decrees in lawsuits brought against the City of Philadelphia for police misconduct; reports by an Integrity and Accountability Officer (“IAO”) appointed by the City to assess the Philadelphia Police Department, particularly with respect to the manner in which police misconduct complaints were investigated; and documents related to 25 other cases involving claims of wrongful conviction caused by PPD misconduct, including newspaper articles, pleadings, depositions, court filings, interviews, and homicide files. (Lynch Rpt. at 11-13; Ex. A.) Mr. Lynch opined, based on the documents he

reviewed, as follows: since the late 1970s, PPD leadership has been on notice that its officers, especially the detectives in its Homicide Division, have routinely violated the most basic legal limitations on law enforcement officer conduct. They have engaged in the outright fabrication of evidence, the coercion of witness testimony while recklessly disregarding the falsity of such testimony, and the suppression and concealment of material evidence. They have also routinely ignored leads pointing to the true perpetrators of criminal offenses. Through repeated publicity about notorious scandals, PPD leadership have learned of this conduct and, in response, have paid lip service to the need for reform. In each instance, however, PPD leadership has failed to implement meaningful changes in practice that remedy and prevent instances of misconduct.

This is most apparent in the longstanding failures of PPD’s disciplinary system. Law enforcement agencies cannot secure their employee officers’ compliance with legal obligations without the promise of accountability for misconduct. Investigations that give officers the benefit of the doubt and mete out minimal, if any, discipline even in cases of gross misconduct, provide officers with the clear message that they can violate established legal and departmental rules with impunity. As such, the lack of effective discipline fosters a culture of misconduct that leads to the routine violations of civilians’ rights under the U.S. Constitution.

(Lynch Rpt. at 27-28.) Mr. Lynch also specifically addressed evidence that he reviewed with respect to wrongful conviction lawsuits brought against Detective Santiago and the City of Philadelphia by the following: (1) Anthony Wright, who was convicted of the 1991 rape and murder of an elderly woman based on a coerced confession obtained by Detective Santiago and spent nearly 25 years in prison before his conviction was overturned based on DNA evidence that excluded him as the perpetrator (id. at 15-16); (2) Percy St.

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