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Harold Hall, who spent 19 years in prison for two murders that he didn't commit, can sue the Los Angeles Police Department for his wrongful conviction.
Procedurally, Hall's case was shaky, but the Ninth Circuit Court of Appeals ruled Tuesday that the "exceptional circumstances" in his case persuaded the court to allow Hall to amend his complaint in order to "avoid manifest injustice."
Hall became the target of the double murder investigation after being arrested for a robbery in August 1985. Hall, who had previously testified for prosecutors in a drive-by shooting, was housed with other informants in the jail. The Ninth Circuit explains:
While his segregation from the general population may have helped protect Hall from physical attacks, he became a sitting duck for predatory informants. Three experienced jailhouse informants, with cases pending, discussed [Nola] Duncan's murder with Hall. Those informants then falsely implicated Hall in [Duncan and David Rainey's] murders by concocting a story that Hall had confessed to the murders.
Hall agreed to admit guilt only after 17 hours of interrogation during which he was handcuffed, denied food and never advised of his rights, the Los Angeles Times reports.
The Ninth Circuit granted his habeas petition in 2004, upon determining that Hall's conviction was predicated on falsified documents and his confession was given while he was under duress. The state did not retry him.
Hall sued the city for civil rights violations, but didn't claim possible Fifth Amendment violations. The district court held that the coerced interrogation claim was not cognizable under the second Devereaux prong -- that the individual detectives used such abusive and coercive investigative techniques that they knew or should have known that those techniques would yield false information -- and concluded that even if Devereaux applied, Hall had not raised triable issues of fact to support his fabrication-of-evidence claim.
On appeal, the Ninth Circuit affirmed the district court's summary judgment ruling on the fabrication-of-evidence claim. The appellate court remanded the suit with instructions to allow Hall to plead an explicit Fifth Amendment violation.
Senior Circuit Judge Dorothy W. Nelson, wrote, "Justice eluded Hall when he served 19 years in state prison for a crime he did not commit. And justice will elude Hall yet again without the opportunity to amend his complaint and let a jury decide whether he deserves monetary compensation for his unlawful incarceration."
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