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Crafton v. District of Columbia

United States District Court, D. Columbia

September 23, 2015

Kim Crafton, Plaintiff,
v.
District of Columbia, et al., Defendants

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          For KIM CRAFTON, Plaintiff: Afshin Pishevar, PISHEVAR & ASSOCIATES, P.C., Rockville, MD.

         For DISTRICT OF COLUMBIA, JAMES TRAINUM, In His Official and Individual Capacity, Defendants: Stephanie Litos, LEAD ATTORNEY, OFFICE OF THE ATTORNEY GENERAL FOR THE DISTRICT OF COLUMBIA, Washington, DC.

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         MEMORANDUM OPINION

         Amit P. Mehta, United States District Judge.

         I. INTRODUCTION

         Sometimes even conceded wrongs cannot be addressed by the judicial process. This is such a case. In February 1994, Plaintiff Kim Crafton was detained for ten months on the charge of felony murder, a crime which she did not commit. According to Plaintiff, she was arrested and charged because Defendant James Trainum, at the time a detective with the District of Columbia Metropolitan Police Department, obtained a false confession from her using coercive interrogation tactics. He also suppressed and disregarded evidence demonstrating her innocence. The charges against Plaintiff ultimately were dismissed without prejudice.

         Fast forward 20 years to August 2013. Defendant Trainum had become a lecturer and teacher on police interrogation tactics and regularly discussed Plaintiff's case in his presentations. He admitted on a radio program that he had coerced Plaintiff's confession and had disregarded evidence that exculpated her. Upon learning of Trainum's " confession," Plaintiff filed this suit on September 3, 2014, against Trainum and the District of Columbia, asserting claims under Section 1983, as well as common law claims of intentional infliction of emotional distress and malicious prosecution.

         Defendants have moved to dismiss all claims on the ground that they are barred by the statute of limitations. Plaintiff counters that her claims are timely because she did not " discover" her claims until Trainum's public acknowledgement of his wrongful acts. Notwithstanding that the serious wrongs Plaintiff alleges will go unredressed, the court agrees with Defendants that her claims are barred by the statute of limitations. The court therefore grants Defendants' motion and dismisses Plaintiff's Complaint and this action in its entirety.

         II. BACKGROUND

         A. Facts Alleged in the Complaint

         1. Plaintiff's Wrongful Arrest and Detention

         In 1994, Plaintiff Kim Crafton was living in a homeless shelter in the District of

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Columbia. Compl., ECF No. 1, ¶ 5. At that time, Defendant James Trainum was a detective with the District of Columbia Metropolitan Police Department (" MPD" ), who " was investigating the brutal abduction, robbery, and murder of Lawrence O'Connell[,] whose body was found bound and beaten on the banks of the Anacostia River." Id. ¶ 8. Trainum detained Plaintiff based on a tip that she matched a " grainy photograph from an ATM used by the murderer(s) and a composite sketch based on a description by a clerk in a liquor store where the credit card [taken from O'Connell] was used." Id. ¶ 9. Trainum proceeded to conduct a " lengthy, grueling" 17-hour videotaped interrogation of Plaintiff during which he used " flawed techniques of interrogation," including sleep deprivation, that " he had been taught by the Metropolitan Police Department, known as 'Reid training.'" Id. ¶ ¶ 9, 12, 14-15. Plaintiff made several incriminating statements during the interrogation and, in the end, confessed to robbing and murdering O'Connell. Id. ¶ 16. According to Plaintiff, " Trainum obtained these false, incriminating statements through coercive and unconstitutional tactics, including improper psychological intimidation and pressure and unduly oppressive conditions of confinement such that the resulting statements and confession were neither true nor the product of Plaintiff's free will." Id. ¶ 17. Plaintiff thereafter was arrested, charged with felony murder, and detained pending her trial. Id. ¶ 21. Several weeks later, she recanted her confession but the charges remained pending. Id. ¶ 22.

         According to Plaintiff, Trainum's wrongful conduct persisted after he coerced her to confess. Trainum " affirmatively endeavored to stretch and manipulate the facts and the evidence to fit the false hypothesis that she was guilty of the crime." Id. ¶ 13. Specifically, Plaintiff alleges that Trainum disregarded and failed to disclose evidence that clearly demonstrated her innocence. Id. ¶ ¶ 18, 20. For instance, after her recantation, Trainum reviewed the log books at the homeless shelter where Plaintiff had been living and determined that she could not have been at the scene of the murder when the crime occurred. Id. ¶ 23. Secret Service and FBI handwriting experts concluded that the shelter log books bearing Plaintiff's signature matched her handwriting. Id. ¶ 24. They also determined that the handwriting on the credit card receipts signed by O'Connell's assailant " unequivocally was not that of Plaintiff." Id. This evidence was not turned over to Plaintiff's counsel. Id. ¶ 25. Trainum also disregarded other evidence pointing to Plaintiff's innocence. He ignored contradictory statements made during Plaintiff's interrogation, id. ¶ 18, and disregarded Plaintiff's statement that she was seven months pregnant when O'Connell's murder occurred, even though he knew the suspect " in the ATM photo was clearly not pregnant." Id.

         After Plaintiff spent ten months in jail awaiting trial, the charges against her were dismissed without prejudice for insufficient evidence. Id. ¶ 26.

         2. Trainum's " Confession"

         Plaintiff alleges that she first learned of Trainum's wrongdoing nearly twenty years later. On August 31, 2013, she received a letter from producers of the radio program " This American Life," who informed her that Trainum was teaching and lecturing on police interrogation tactics and discussing Plaintiff's case in his presentations. Id. ¶ 28A.[1] The show's producers asked to

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speak with her about her case. Id. Plaintiff agreed, and on September 12, 2013, they played for her an audio recording of an interview during which Trainum " admitted that he had coerced the confession of Plaintiff; had ignored or disregarded exculpatory evidence in his charge towards an arrest and conviction in [Plaintiff's] murder case; and, that Plaintiff was, in fact, innocent." Id. ¶ 28B. Plaintiff asserts that she " had no notice that the false confession she gave in 1994 had been coerced by Trainum's wrongful interrogation and actions until hearing [his] recorded admissions." Id. ¶ 29B.

         Then, on September 23, 2013, Plaintiff and Trainum participated in a conference call arranged by the show. On the call, " Trainum repeated his admissions that he had coerced the confession of Plaintiff; had ignored or disregarded exculpatory evidence in his charge towards an arrest and conviction in the murder case; and, that Plaintiff ...


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