Canen v. Chapman

A resident of Elkhart’s housing for low-income elderly people and disabled adults was strangled to death. Canen and Royer, recipients of disability benefits, were also residents. They were convicted of felony murder in Indiana state court in 2005. Seven years later, Canen’s conviction was vacated after Chapman, the state’s fingerprint expert, recanted his testimony, conceding that he mistakenly had identified a latent fingerprint found at the crime scene as belonging to Canen. Chapman only was trained to compare “known prints” (i.e., digital, ink, or powder fingerprint exemplars), not “latent prints” (i.e., invisible, unknown fingerprints found at a crime scene), and lacked the necessary qualifications to identify the latent print. He had not disclosed his lack of training in the state proceeding. Canen sued Chapman under 42 U.S.C. 1983, claiming that he had withheld his lack of qualification to perform latent fingerprint analysis in violation of Brady v. Maryland. The district court dismissed, holding that Chapman was entitled to qualified immunity. The Seventh Circuit affirmed. Chapman’s failure to disclose that he was not trained as a latent print examiner is not a violation of any clearly established right, and, to the degree that Canen’s claims are premised on the preparation or presentation of his testimony, absolute immunity protects him. View "Canen v. Chapman" on Justia Law