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Date: 08-13-2024
Case Style:
Estate of Isaiah Andrews v. City of Cleveland, Ohio, et al.
Case Number: 1:22-CV-250
Judge: James S. Gwin
Court: United States District Court for the Northern District of Ohio (Cuyahoga County)
Plaintiff's Attorney:
Defendant's Attorney: William M. Menzalora
Description:
Justice went to hell in Cleveland, Ohio when Isaiah Andrews was convicted in 1974 for murdering his wife.
Isaiah Andrews spent nearly 46 years in prison for the alleged 1974 murder of his wife. After an Ohio court determined that the government failed to turn over key exculpatory evidence, Ohio granted Andrews a new trial, and a new jury found him not guilty. He filed a § 1983 suit against the City of Cleveland and some of the officers involved with his case.
Sometime between 7:00 am and 2:00 pm on September 18, 1974, someone fatally stabbed Regina Andrews. Cleveland police found her body in a park wrapped in bed linens. The scene offered some clues. A nearby newspaper showed a bloody palm print, and a blood-stained pillowcase carried a tag from Howard Johnson's Motor Lodge.
Officers went to the Howard Johnson's motel. The desk clerk told police that bed linens were missing from the room of Willie Watts. The next morning, police arrested Watts for Regina's murder. His custody did not last long. The police released Watts after he established an alibi for the morning of September 18.
The police identified Regina's husband, Isaiah Andrews, as another suspect. No physical evidence linked him to the scene. But the State had recently released Andrews for a previous murder, he admitted to arguing with Regina shortly before her death, and his polygraph results and alibi did not add up. An Ohio grand jury indicted Andrews for murder, and a jury found him guilty in 1975. He received a life sentence.
During the next 45 years, Andrews periodically pursued postconviction relief in state court. In 2020, the State granted Andrews a new trial after finding that he never received exculpatory evidence concerning Watts. In October 2021, the new jury found Andrews not guilty.
On February 14, 2022, Andrews filed this § 1983 action against the lead detectives, William Hubbard and Ernest Rowell, eight other officers, and the City of Cleveland. The lawsuit alleged that the officers and the City violated Andrews' Fourteenth Amendment right to due process by withholding exculpatory evidence. Because Hubbard, Rowell, and some of the other officers had died by the time of the lawsuit, the district court allowed Andrews to substitute the common administrator of their estates as the defendant. When Andrews died later in 2022, the court permitted his estate administrator to litigate the case.
The district court ruled as a matter of law for all of the defendants. It dismissed the claims against the Hubbard and Rowell estates because Andrews had waited too long to bring his claims against them. See Ohio Rev. Code § 2117.06. And it granted summary judgment in favor of the City of Cleveland because its police, as opposed to the prosecutor, did not withhold exculpatory evidence.
Federal civil rights laws play a key role in the balance between national and state authority. Perhaps the most pivotal of these laws, 42 U.S.C. § 1983 creates a cause of action to vindicate federal rights against state officials and governments. At the same time that federal law creates this action, it leaves state law to fill in the gaps over how these actions work. See Bd. of Regents of Univ. of State of N.Y. v. Tomanio, 446 U.S. 478, 483-84 (1980). When federal law is "deficient" in explaining how an action works, state law governs the proceedings as long as it "is not inconsistent with the Constitution and laws of the United States." 42 U.S.C. § 1988(a).
The District Court held that Plaintiff could not sue the estates of the officers who withheld exculpatory evidence.
Outcome: The district court rejected his claims as a matter of law. It found that Andrews had waited too long after his release to file this lawsuit against the deceased officers, and that he failed to show that it was the police rather than the prosecutors who violated his rights.
The district court correctly held that Andrews could no proceed agaisnt the Hubbard and Roswell's estate administrators.
For these reasons, we reverse the district court's grant of summary judgment to the City of Cleveland and remand for the district court to consider whether a City policy caused the Brady violation. We otherwise affirm the district court's dismissal of Andrews' claims against Hubbard and Rowell.
Affirm on the first issue and reverse and remand on the second.
Plaintiff's Experts:
Defendant's Experts:
Comments: