CHICAGO (CN) - A man cleared of his ex-girlfriend's murder after 13 years in prison cannot sue the police over evidence that prosecutors withheld, the 7th Circuit ruled.
Alan Beaman, was convicted in 1995 of the murder of his ex-girlfriend at Illinois State University, Jennifer Lockmiller.
Beaman's fingerprints were found on the alarm clock whose cord had been used to strangled Lockmiller. She was also stabbed in the chest with scissors.
The Illinois Supreme Court overturned Beaman's conviction 13 years later, however, based on the state's withholding of exculpatory evidence that painted Stacey Gates and Larbi John Murray as alternative suspects.
Though Beaman sued various police and prosecutors for alleged violations of his civil rights, only claims against the town of Normal, Ill., and three officers were remaining when U.S. District Judge Joe McDade granted them summary judgment last year.
That ruling acknowledged that defense counsel had no way of knowing about "Murray's erratic behavior from steroids, history of domestic assault and possible evasion during the polygraph," which "suggest he could have been the culprit."
But McDade held that none of the remaining defendants had control over the withheld information, and therefore Beaman could not hold them liable.
Only the prosecutor, previously dismissed from the case, knew about Murray's checkered past, and only the police knew about the polygraph failure, according to the ruling. The officers were granted immunity because then-existing Illinois state law did not give them a clear duty to disclose that failure.
The 7th Circuit affirmed the ruling Tuesday after hearing arguments in September.
"Beaman does not explain what other evidence he would have presented that would point to Gates as the murderer, even if the trial court had allowed him to do so," Judge Ann Williams wrote for a three-person panel. "It is highly unlikely that the trial court would have allowed evidence showing that Gates was the actual murderer given his solid alibi, and, as it stands, Beaman has presented no evidence to debunk Gates's alibi."
Some months after Beaman's trial concluded, the U.S. Supreme Court confirmed that the failure by a state to disclose a witness's polygraph failure does not deprive a defendant of material evidence, because that evidence is not admissible at trial.
"Even if the relevant inquiry was what the Illinois Supreme Court decided," when it overturned Beaman's conviction, "that court's determination in 2008 that the polygraph test could have affected the trial does not answer the question of whether, in 1995, it was clearly established that the officers needed to turn over inadmissible polygraph reports," Williams said.
The panel added that, even if the evidence might have been material, "unfortunately for Beaman," absolute prosecutorial immunity shields the former assistant state's attorney, and the defendant police officers should not be held responsible.
"While this ruling results in a situation where Beaman cannot hold anyone accountable for the government's failure to turn over Brady evidence, the solution should not be to punish the police officers - who did turn over the evidence to the prosecutor - for the prosecutor's failure in judgment," the opinion concluded.
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