Defendant's Attorney: Kathryn Anne Lloyd

Description: Greenbelt, Maryland personal injury lawyer represented the Plaintiff who sued for violation of his civil rights.

After receiving information from other law enforcement officers identifying Angelo Jackson as a suspect in a double murder in Montgomery County, Maryland, the lead homicide investigator, Detective Michael Carin, reported that information in an affidavit to support his application for a warrant to arrest Jackson. After “clearing” the application
with his supervisor and the state prosecutor, Detective Carin presented it to a commissioner, who issued a warrant to arrest Jackson. After Jackson was arrested and detained, Detective Carin also testified before the grand jury, presenting the same identification information, as well as another identification made by an eyewitness. The grand jury indicted Jackson for the two murders.

As Detective Carin continued the investigation, however, he uncovered exculpatory evidence, including latent prints, DNA, and cellphone records supporting Jackson’s alibi, and Carin presented that evidence to the state prosecutor. Upon receiving the DNA test results exculpating Jackson, the state prosecutor dropped all charges, and Jackson was
released after having been detained for 65 days.

Jackson commenced this action against Detective Carin, alleging, in support of his federal and state claims, that Carin’s affidavit in support of the warrant and his testimony before the grand jury were deliberately false or were provided with reckless disregard for the truth. Jackson also alleged that if the commissioner and the grand jury were presented
with the truthful evidence then available, they would not have found probable cause for his
arrest and indictment, respectively.

The district court, in assessing Detective Carin’s affidavit, deleted from it evidence that was reasonably disputed by Jackson as false, and found that, even with that disputed material deleted, the affidavit provided probable cause to arrest Jackson. The court granted Detective Carin summary judgment on all of Jackson’s claims, finding also that Detective
Carin was qualifiedly immune from liability on Jackson’s federal claims.

While we are sympathetic to Jackson for the mistaken identification that led to his wrongful arrest and detention, we nonetheless find that we must affirm the district court’s judgment, concluding that Detective Carin did not violate the standards imposed on him by law in pursuing the investigation as he did.

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Outcome: Dismissal affirmed.

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