Claim against Rikers Island Guards allowed to Proceed: Plaintiff alleges that Rikers Island Guards B
The Plaintiff, Axel Rentas, was an inmate at Rikers when he alleged that officers used excessive force against him and then fabricated evidence that resulted in a prosecution and prolonged detention. In 2007, Rentas was serving a misdemeanor sentence and was scheduled to be released weeks before he was forcibly moved from one cell to another. A dispute ensued. Although what happens next is disputed, it is clear that the Plaintiff suffered significant injury at the hands of the Rikers Island guards: a fractured eye socket, bruises and abrasions all over his body along with bleeding in the lungs. The officers claimed injuries too (omitted from the record here) and Rentas was charged with felonious assault. After being charged and detained during this time, Rentas was acquitted of these charges.
Rentas claimed that the beating and subsequent reports claiming that he, Rentas, feloniously assaulted the city officials was feigned and used to keep him in jail longer. Although some reports were entered into evidence, others were held inadmissible by the district court. After a jury verdict was rendered in Rentas' favor, this appeal followed. Of major focus is malicious prosecution:
Rentas appeals the award of summary judgment to Defendants on his malicious prosecution claim. At issue is the absence of probable cause: While it is true that “a grand jury indictment gives rise to a presumption that probable cause exists and a claim for malicious prosecution . . . thereby is defeated,” McClellan v. Smith, 439 1 F.3d 137, 145 (2d Cir. 2006), “the presumption may be rebutted by evidence of . . . wrongful acts on the part of police,” including “fraud, perjury, [or] the suppression of evidence.” Id. (quoting Colon v. City of New York, 60 N.Y.2d 78, 83 (1983)). For example, when an “officer provide[s] false information to a prosecutor, what prosecutors do subsequently has no effect whatsoever on the . . . officer’s initial, potentially tortious behavior.” Cameron, 598 F.3d at 63. But if the prosecution relied on independent, untainted information to establish probable cause, a complaining official will not be responsible for the prosecution that follows. See Townes v. City of New York, 176 F.3d 138, 147 (2d Cir. 1999). In that situation, “the chain of causation between a police officer’s unlawful arrest and a subsequent conviction and incarceration [would be] broken by the intervening exercise of [the prosecutor’s] independent judgment.” Id.
The Second Circuit found that the district court erred: alleged statements by the inmate witnesses, quoted by the officers who allegedly feigned these documents, were not enough to break the "chain of causation" if it was contained in these documents. Pp. 10. The Second Circuit also finds that the district court incorrectly faulted Rentas with failing to produce independent evidence that the defendants lied to prosecutors. Additionally, Rentas offered photographic evidence beyond his testimony that controverted the defendants' story - it did not appear that there were any abrasions or bruises on his hands. Quickly disposing of the issue of whether malice existed, the Second Circuit held that malice can be inferred and, in this case, was inferred by Rentas' sworn testimony.
The case is Rentas v. Ruffin, 14-2475-cv (L) (2d Cir. Mar. 8, 2016).
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