Second Circuit Throws Out Malicious Prosecution Suit Against NYPD Detective
The ruling, issued Tuesday, reversed a 2017 decision by U.S. District Judge Jack B. Weinstein of the Eastern District of New York, which denied NYPD Detective Fortunato Tranchina's motion for summary judgment and allowed the case to proceed to trial.
September 11, 2019 at 02:56 PM
5 minute read
The U.S. Court of Appeals for the Second Circuit has ruled that a Queens detective was shielded from claims of malicious prosecution, despite his failure to inform a grand jury about problems with a witness' identification of a suspect in the 2007 robbery of a sporting goods store.
The ruling, issued Tuesday, reversed a 2017 decision by U.S. District Judge Jack B. Weinstein of the Eastern District of New York, which denied NYPD Detective Fortunato Tranchina's motion for summary judgment and allowed the case to proceed to trial.
Weinstein had ruled that the failure of Tranchina and prosecutors to notify the grand jury of the "shaky ground" for the witness' identification testimony could create the impression of collusion between the two. That finding, Weinstein said, was enough to wipe out the probable cause that initially led to Maxie DaCosta and strip the Tranchina of his qualified immunity defense, which protects government officials from being sued for actions taken in their official capacity.
A three-judge panel of the Manhattan-based appeals court, however, said that "officers of reasonable competence" could disagree about whether the supposed misstep actually tainted the investigation.
"We therefore conclude that Tranchina had at least arguable probable cause to pursue the prosecution and was entitled to qualified immunity, despite these later events," the panel wrote in a six-page summary order directing the lower court to enter a judgment in favor of the detective.
According to court documents, Tranchina told the grand jury that one of three eyewitnesses had picked DaCosta out of a police lineup. That eyewitness, who was a victim of the robbery, saw a wanted poster for DaCosta on TV months after the robbery in connection with unrelated homicide and escape charges.
The charges against DaCosta were dismissed in 2012 after it was revealed that police possessed a videotape showing that he was not the person who committed the crime. DaCosta sued Tranchina and the NYPD, saying that other two eyewitnesses did not identify DaCosta and that the grand jury was never shown the videotape.
According to Weinstein, the case presented a set of "rare circumstances" that rebut the presumption in a grand jury proceeding that there was probable cause to commence a criminal action.
"There is a genuine dispute as to whether there was probable cause to institute and maintain the criminal action against plaintiff for robbery and whether the grand jury indictment was sufficiently supported by probable cause," he wrote in memorandum denying Tranchina's motion for summary judgment.
The appeals court, however, sided with attorneys from the New York City Law Department, who argued that Tranchina's conduct was "entirely proper" because the witness, Mohammad Sarwar, had named DaCosta without any police involvement and later confirmed the identification through a photo array and an in-person lineup.
They also refuted Weinstein's finding that Tranchina had improperly withheld the videotape from the grand jury, saying that the ruling went against longstanding Supreme Court precedent holding that grand juries need not be presented with exculpatory evidence.
"Because there was at least arguable probable cause to believe DaCosta could be successfully prosecuted, Detective Tranchina is entitled to qualified immunity from DaCosta's … malicious prosecution claim," MacKenzie Fillow, assistant corporation counsel, wrote in a filing with the Second Circuit.
The appeals court on Tuesday agreed that Tranchina had arguable probable cause to proceed based on Sarwar's identification and sent the case back to the district court for final resolution.
"No intervening facts either cast doubt on that initial identification or made it apparent that the charges against DaCosta were 'groundless,'" the panel said.
A spokesman for the Law Department praised the decision in a statement Wednesday.
"Qualified immunity protects officers who make reasonable policing decisions with information known to them at the time. We're gratified the court agreed that this is one such case where the officer was entitled to the defense," Nicholas Paolucci, press secretary and director of public affairs, said.
An attorney for Tranchina did not immediately return a call seeking comment on the case.
The panel included Judges John M. Walker Jr., Raymond J. Lohier Jr. and Susan L. Carney of the U.S. Court of Appeals for the Second Circuit.
DaCosta was represented on appeal by Scott A. Korenbaum, as well as Kim E. Richman of Richman Law Group in Brooklyn.
Fillow and Devin Slack of the Law Department represented Tranchina.
The case was captioned DaCosta v. Tranchina.
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