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Friday, January 15, 2021

Court of Appeals Upholds $22 Million Jury Verdict for Wrongful Conviction

The Seventh Circuit Court of Appeals recently upheld a jury award of $22 million in a wrongful conviction case against the City of Chicago. Fields v. City of Chicago.

In 1986, Nathson Fields and his co-defendant Earl Hawkins were convicted of murder by a Cook County Circuit Court Judge. Twelve years after the trial, in 1998, those convictions were overturned based on evidence that Hawkins’s attorney had bribed the Judge to secure an acquittal and that the Judge had became concerned that he was being investigated by law enforcement during the trial and returned the bribe. Fields was then retried for the murder. Under a plea agreement, co-defendant Hawkins pled guilty to lesser charges in exchange for testifying against Fields in his murder trial. The plea agreement also stated that it was “the intent of both parties that Hawkins remain in custody until he reaches 72 years of age,” which would be in 2027.

Fields was acquitted in the retrial in 2009. Following his acquittal, Fields filed suit, alleging civil rights and state law claims against the City of Chicago and Chicago police detectives. Fields argued that the detectives pulled Fields as a suspect out of the air, fabricated witness identifications, and failed to provide the police investigative “street file” to Cook County prosecutors. Fields contended that the detectives’ failure to turn over street files to prosecutors was a widespread practice within the Chicago police department, which deprived defense attorneys of the opportunity to fully represent the accused at trial. After a mistrial, a second trial took place in April 2014, and at the close of the trial, a jury found in favor of Fields on a due process claim against one of the police detectives, and in favor of the City and detectives on the remaining claims. 

Following the end of the trial, new evidence came to light that Hawkins was granted a new plea-deal in exchange for testifying against Fields at trial— Hawkins was released on parole three months after the trial, which was 13 years earlier than his original 42 year sentence. Fields and his attorney were not made aware of the deal until after the trial. Fields moved for a new trial on the basis that his attorney could have used the evidence of the new plea deal to discredit Hawkins’s testimony, and as a result, he was deprived of a fair trial. The district court granted Fields’s motion for a new trial, and after a month-long trial, a jury found in favor of Fields against the detectives on his civil rights and state law claims, and against the city on Field’s civil rights claim under §1983. The jury awarded Fields over $22 million in damages. The City and detectives appealed to the Seventh Circuit Court of Appeals, arguing that the district court improperly granted Fields’s motion for a new trial and that the jury verdict should be overturned.

On appeal, the Seventh Circuit found that Fields was unable to fully and fairly present his case without the newly discovered evidence of Hawkins’s new plea-deal with prosecutors. The Court reasoned that the evidence that Hawkins’s trial testimony would lead to his near-immediate release would have severely damaged the City and detectives’ case—and could reasonably have produced a different outcome. Therefore, the Court upheld the district court’s decision to grant a new trial.

The Court also upheld the jury trial’s verdict against the City. In rejecting the City’s argument that Fields failed to show a widespread practice or policy required to establish a civil rights claim, the Court reasoned that Fields presented evidence of a “systemic underproduction of police reports of exculpatory evidence to prosecutors and defense attorneys,” which went well beyond Fields’s case. As a result, the Court held that there was a reasonable basis for a jury to find for Fields on the civil rights claim and upheld the jury trial’s verdict in his favor against the City.

Post authored by Rain Montero & Julie Tappendorf, Ancel Glink


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