Wright v. City of Philadelphia

229 F. Supp. 3d 322, 2017 U.S. Dist. LEXIS 5918, 2017 WL 167970
CourtDistrict Court, E.D. Pennsylvania
DecidedJanuary 17, 2017
DocketCIVIL ACTION No. 16-5020
StatusPublished
Cited by33 cases

This text of 229 F. Supp. 3d 322 (Wright 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
Wright v. City of Philadelphia, 229 F. Supp. 3d 322, 2017 U.S. Dist. LEXIS 5918, 2017 WL 167970 (E.D. Pa. 2017).

Opinion

MEMORANDUM

Pratter, United States District Judge

I. Introduction

Anthony Wright sued the City of Philadelphia and 11 individuals, all of whom were members of the Philadelphia Police Department during the time relevant to this action, pursuant to 42 U.S.C. § 1983 and Pennsylvania state law. This action arises out of the investigation and prosecution that resulted in Mr. Wright’s wrongful conviction for a 1991 rape and murder. Mr. Wright alleges that the Defendants, working individually and in concert, fabricated evidence, coerced a false confession, and withheld exculpatory evidence, among other alleged misconduct, all of which led to Mr. Wright’s arrest, prosecution, and conviction for a crime he did not commit. After DNA evidence conclusively excluded Mr. Wright as the source of the biological evidence found at the crime scene, Mr. Wright’s conviction was vacated. Upon retrial, a jury acquitted Mr. Wright of all charges. Mr. Wright spent 25 years in prison as a result of his wrongful conviction.

Mr. Wright now brings an eight-count complaint against Defendants for (i) malicious prosecution pursuant to § 1983 (Count 1) and Pennsylvania law (Count 8); (ii) due process violations (Count 2); (in) violating his right against self-incrimination (Count 3); (iv) civil rights conspiracy (Count 4); (v) failure to intervene (Count 5); (vi) supervisory liability (Count 6); and (vii) municipal liability (Count 7). Defendants have moved to dismiss (i) Counts 2-4 on statute of limitations grounds; (ii) Count 7 for failure to sufficiently plead a Monell claim; and (iii) all claims against Detectives David Baker, Dennis Dusak, and Eugene Wyatt for failure to state a claim. Because the Court concludes that Mr. Wright’s claims did not accrue until after the criminal proceedings against him were favorably terminated, and because Mr. Wright has stated plausible claims for relief against the City and Detectives Baker, Dusak, and Wyatt, the Court will deny the motion in its entirety.

II. Allegations in the Complaint 1

On October 18, 1991, 77 year-old Louise Talley was raped and murdered in her North Philadelphia home. While DNA evidence would eventually exonerate Mr. Wright, and conclusively implicate an individual named Ronnie Byrd, Mr. Wright was wrongfully convicted of Ms. Talley’s [326]*326rape and murder and served 25 years in prison.

Officers Dennis Dusak, Manuel Santiago, and Thomas Burke (the “on-scene Defendants”) were the first officers to arrive at the crime scene. Detective Dusak, as the lead detective, was responsible for overseeing the investigation of Ms. Talley’s rape and murder. The on-scene Defendants’ initial review of the crime scene revealed (i) that Ms. Talley was stabbed to death with a 12-inch metal knife with an eight-inch blade; (ii) evidence that suggested the crime’s perpetrator stole a TV; and (iii) the presence of masculine clothing items, including a black Chicago Bulls shirt, blue jeans with suede material, and Fila sneakers. Detectives Dusak and Santiago prepared detailed reports documenting their examination of the crime scene.

While investigating the crime scene, the on-scene Defendants learned that an individual named Roland St. James had been seen attempting to sell Ms. Talley’s stolen TV. After following this lead, the on-scene Defendants determined that Mr. St. James, as well as a friend of Mr. St. James, John “Buddy” Richardson, had been in possession of Ms. Talley’s TV and other items of stolen property. Based on this finding, the on-scene Defendants instructed other police officers to take Messrs. St. James and Richardson into custody. Once in custody, the on-scene Defendants and Detectives James Morton and David Baker discussed details of Ms. Talley’s murder learned by the on-scene Defendants with Messrs. St. James and Richardson. After Messrs. St. James and Richardson were provided details of Ms. Talley’s rape and murder, Detective Morton took Mr. St. James’s formal statement concerning the crime and Detective Baker took Mr. Richardson’s formal statement. The detectives never reported their pre-statement discussions with Messrs. St. James and Richardson, including statements made by Messrs. St. James and Richardson by which they incriminated themselves and exculpated Mr. Wright, and the fact that certain detectives provided Messrs. St. James and Richardson with details of the crime. The on-scene Defendants simply reported that neighborhood witnesses, including Messrs. St. James and Richardson, implicated Mr. Wright in Ms. Talley’s death. Neither Mr. St. James nor Mr. Richardson were ever charged in connection with Ms. Talley’s death or for being in possession of Ms. Talley’s stolen property. The police released both individuals after they each implicated Mr. Wright in the crime.

The following day, Detective Santiago and Sergeant Burke approached Mr. Wright, who had just turned 20 years-old, at his home. The officers asked Mr. Wright if he would accompany them to the police station to discuss a murder in the area, telling Mr. Wright that they would bring him right back. Upon their arrival at the police station, however, Detective Santiago placed Mr. Wright in an interrogation room. Detective Santiago and Sergeant Burke, joined by Detective Martin Devlin (the “interrogating Defendants”), interrogated Mr. Wright for hours, without informing Mr. Wright of his Miranda rights and without recording the deposition by audio or visual means. Detective Devlin, who had not previously taken part in the investigation, was included in the interrogation at the urging of Officers Santiago, Burke, and Dusak for the express purpose of coercing a confession. During the course of the interrogation, the interrogating Defendants accused Mr. Wright of Ms. Talley’s murder and falsely claimed that the police had eyewitnesses and physical evidence against him. At no point did the police tell Mr. Wright he was free to leave or that he could call a lawyer. Nor did the police allow Mr. Wright to call his mother, [327]*327despite his repeated request that he be permitted to do so. Mr. Wright maintained his innocence for hours, repeatedly providing the interrogating Defendants with details of his movements for the previous few days.

After the interrogating Defendants failed to obtain a confession, the interrogating Defendants handcuffed Mr. Wright to a chair and presented him with a nine-page statement handwritten by Detective Devlin. While this statement contained in-culpatory information, Mr. Wright never made any of the statements that the document attributed to him. Rather, the nine-page statement was a narrative of how the Defendants believed the crime occurred and included details meant to match Defendants’ theory of the crime. These details included references to the believed cause of death (stabbing), the perceived sexual assault, and assertions that Mr. Wright wore a black Chicago Bulls shirt, blue jeans with suede material, and black Fila sneakers during the crime. The statement also purported to establish that Mr. Wright informed the interrogating Defendants that the clothes he wore when perpetrating the crime were in his bedroom. The statement did not include the fact that Ms. Talley suffered blunt force trauma to the head, a fact that neither the on-scene nor interrogating Defendants were aware of at the time of Mr. Wright’s interrogation.

When Mr.

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Bluebook (online)
229 F. Supp. 3d 322, 2017 U.S. Dist. LEXIS 5918, 2017 WL 167970, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wright-v-city-of-philadelphia-paed-2017.