The Illinois Supreme Court will allow a man to continue with his lawsuit against a group of downstate police detectives for allegedly helping to lead the effort to wrongly convict him of murder.
The state high court said an appellate court used the wrong standard in determining who was to blame for improperly charging Alan Beaman, of downstate Normal, with the 1993 murder of an Illinois State University student.
Beaman was sentenced to 50 years in prison for first-degree murder in the killing of his ex-girlfriend, Jennifer Lockmiller, who was found dead in her Normal apartment on Aug. 28, 1993.
In 2008, the Illinois Supreme Court determined Beaman’s due process rights were violated since prosecutors failed to disclose evidence that possibly incriminated another ex-boyfriend, Larbi John Murray, including his criminal record of drug use, incidents of domestic violence against another girlfriend and an incomplete lie detector test.
Illinois Supreme Court Justice Thomas Kilbride
The court vacated the conviction and remanded the case to circuit court for further proceedings, but prosecutors dismissed the charges and Beaman was released from prison in June 2008. In April 2013 the state certified his innocence, and Gov. Pat Quinn issued a formal pardon on Jan. 9, 2015.
In January 2010, Beaman filed a civil suit against former Normal Police detectives Tim Freesmeyer, Dave Warner and Frank Zayas, along with prosecutors and other detectives, alleging malicious prosecution and a federal complaint of conspiracy to deprive him of evidence that would’ve cleared him at trial. A federal judge dismissed claims against the prosecutors, and the claims against the other detectives were voluntarily dismissed after discovery revealed they weren’t involved in alleged evidence suppression.
After the judge granted summary judgment in favor of Freesmeyer, Warner and Zayas, the Seventh Circuit Court of Appeals affirmed the decision. Then in April 2014, Beaman filed another civil suit against the detectives and the town, pleading state law claims that had been dismissed without prejudice. This time, a McClean County judge granted summary judgment, saying Beaman didn’t adequately establish his malicious prosecution claim because state’s attorney’s prosecutors made the decision to press charges, not the detectives.
An appellate court again affirmed the decision, which Beaman appealed. The state Supreme Court granted several former prosecutors and others the opportunity to file friend-of-the-court briefs before issuing a unanimous opinion Feb. 7.
Justice Thomas Kilbride wrote the opinion.
Kilbride said malicious prosecution actions must meet strict criteria and the lower courts said Beaman failed to prove the first of five elements, namely, whether or not the detectives influenced the prosecutors to initiate or continue bringing charges against him, while ignoring the other elements.
“This court first addressed whether a defendant who did not directly initiate the criminal proceedings against the plaintiff could be held liable in a malicious prosecution action in Gilbert v. Emmons,” Kilbride wrote, noting that case was decided in 1866. “If the defendant took some affirmative action to ‘advise and encourage the arrest’ that led to the prosecution, then the defendant could be liable.”
Kilbride further discussed the history of how the court considered similar cases, siding with the defendants in determining the only necessary determination is if the detectives’ actions caused the wrongful prosecution. But whereas the appellate court said Beaman had to show the detectives “pressured or exerted influence on the prosecutor’s decision,” Kilbride again went back to Gilbert to note anyone is potentially liable who “played a significant role in causing the prosecution.”
The Supreme Court reverse the judgment and remanded the case to the appellate panel.