2nd Circuit Revives Federal Wrongful Conviction Challenge
Circuit Judge John Walker Jr. and District Judge Michael Shea of the District of Connecticut, sitting by designation, revived the bulk of the claims that had been dismissed by U.S. District Judge Ann Donnelly of the Eastern District of New York in 2017.
January 29, 2019 at 06:30 PM
6 minute read
The dismissed federal civil suit brought by Kareem Bellamy, who served 14 years in prison on a murder charge before new evidence led to his release in 2008, against New York City was reanimated Tuesday by a U.S. Court of Appeals for the Second Circuit panel majority.
Circuit Judge John Walker Jr. and District Judge Michael Shea of the District of Connecticut, sitting by designation, revived the bulk of the claims that had been dismissed by U.S. District Judge Ann Donnelly of the Eastern District of New York in 2017. The majority found ample material issues raised by the handling of the case investigation by two New York City police detectives, and the actions of the Queens District Attorney's Office during prosecution, to warrant a jury's review at trial.
Bellamy was convicted in 1995 of murdering James Abbott in Far Rockaway on the morning of April 9, 1994, based largely on the evidence of two witnesses, and a statement police claimed Bellamy made in the squad car upon arrest.
After serving 14 years of a 25-years-to-life sentence for a depraved indifference murder and weapon possession conviction, Bellamy's habeas petition was granted by a state court after new evidence cast doubt on his guilt.
In 2012, Bellamy filed his federal civil rights suit against NYPD Dets. Michael Solomeno and John Gillen, as well as the city, claiming wrongful conviction and an unfair trial.
On appeal from the district court's granting of summary judgment, Bellamy made nine discrete claims. He alleged that the two detectives fabricated key evidence in the case, failed to disclose numerous key witness statements in violation of Brady, as well as two Monell claims against the city over practices by the Queens prosecutors at trial.
All but one of those claims now head back to the district court.
Bellamy's consistent denial of making, and the detectives failure to properly record, an alleged statement—and its use at trial—as well as a witness' denial about seeing Bellamy that was used at trial to potentially lead jurors astray, and another witness' known contradictory statements to detectives that never were shared with the defense were among those issues the panel majority found the district court improperly dismissed.
The majority likewise reversed the district court's dismissal of two claims under the U.S. Supreme Court's 1978 decision in Monell v. Department of Social Services of City of New York.
Bellamy claimed he suffered a constitutional violation that the city is responsible for when Queens prosecutors failed to disclose the substantially greater relocation benefits a witness received from the office as part of its witness protection program. Bellamy claims this as another Brady violation, as the Queens DA's office, then under the newly minted stewardship of Richard Brown, deliberately failed to inform prosecutors of the full benefits witnesses were receiving.
In this case, despite stating on the stand that she received $100 and relocation from prosecutors, the witness was, in fact, promised, ahead of trial, that the office would relocate her to the tune of $2,800.
Bellamy also claimed that improper statements made by the trial prosecutor, Assistant District Attorney David Guy, during his closing summations amounted to a denial of due process.
The majority panel argued that, in keeping with its line of precedents on the matter, the city's argument that more recent Supreme Court rulings shifted the analysis of responsibility remained unavailing. The city's contention, if adopted, would turn such precedent “on its head,” the majority wrote.
“[U]nder the City's formulation, we would no longer be looking to the intricacies of state law to decide a Monell claim against a prosecutor's office … but would instead look to [the Supreme Court's 2009 decision in] Van de Kamp [v. Goldstein], a decision exclusively assessing federal common law and federal policy,” the majority found.
With the Monell liability established, the majority found material reasons why the Queens DA's failure to disclose the full financial support provided to the witness, as well as Guy's statements at summation—including claiming “I know who committed the murder”—warranted a jury's review.
In his dissent, Circuit Judge Dennis Jacobs argued that the district court was largely correct in its granting of summary judgment to the substantive issues before the appellate court.
In a statement, Bellamy's counsel, private attorney Joel Rudin, called the majority's decision “hugely important.”
“The lower court had dismissed, saying this was no longer a valid claim, but the appeals court emphatically disagreed,” Rudin said, noting the pro bono work attorney Thomas Hoffman did in early phases of the case. “This means that we can now obtain discovery about how many other wrongful convictions the Queens DA's Office obtained through their illegal 'Chinese Wall' policy.”
Despite the majority panel's clear concerns over the handling of the investigation and trial of Bellamy in the 1990s, a spokeswoman from the Queens DA's office presented the appellate reversal and remand as a victory.
“The opinion of the district court powerfully vindicated the office. Two judges from the circuit court panel indicated that issues of fact requiring additional litigation exist, and the third member of the circuit court panel fully supported the opinion from the district court,” the spokeswoman said. “We remain confident that the subsequent appellate litigation will ultimately vindicate our office.”
A spokesman for the city's Law Department said the city was disappointed and is evaluating its legal options.
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