Hall v. City of Los Angeles

Where a plaintiff is convicted of a murder he did not commit, solely on the basis of a coerced confession, and serves nineteen years in prison, but fails to include an explicit Fifth Amendment claim despite alleging sufficient facts to support such a claim, it is manifestly unjust to deny leave to amend the complaint.

“Hall appeal[ed] the district court’s order granting summary judgment to the City of Los Angeles and individual defendants Mark Arneson and Kenneth Crocker…” on his 42 U.S.C. § 1983 claim. In his pleading Hall had asserted a Fourteenth Amendment Due Process violation and claimed “that the detectives coerced his confession and then used that confession to secure his conviction.” The Ninth Circuit affirmed the order granting summary judgment because it found that the claimed violations were in fact violations of the Fifth Amendment, not the Fourteenth Amendment, and Hall had not asserted a Fifth Amendment claim in his pleading. However, the Court noted that Hall had sought leave to amend his pleading, and the district court had denied the motion. The Court also noted that by appealing the final order, Hall had “implicitly brought all of the district court’s subordinate orders within the jurisdiction of [the Court].” Finally, the Court reasoned that it could consider the issue of amending the pleadings sua sponte because (1) the result otherwise would be manifestly unjust, since Hall was convicted of a murder he did not commit solely on the basis of a confession obtained by the coercive interrogation at issue in this case, and (2) the defendants would not be prejudiced since Hall’s complaint gave them “fair notice of the facts supporting the coerced interrogation claim.” The Ninth Circuit held that the district court erred in denying Hall’s motion for leave to amend his complaint. AFFIRMED in part, REVERSED in part, REMANDED.