David Johns Bryson spent seventeen years in jail after Joyce Gilchrist of the Oklahoma City Police Department testified that Bryson’s hair and semen samples matched evidence from a crime scene. Bryson’s 1983 conviction was vacated after a new DNA test cleared him. Even so, it took another three and a half years for a judge to dismiss the charges against him. Bryson successfully sued Gilchrist for $16.5 million, after discovering that the chemist’s own lab results showed that his sample was inconsistent with the semen at the scene.
A federal judge, however, ruled that the city could not have predicted the falsified lab results and was, therefore, not liable. On appeal, the Tenth Circuit Court of Appeals upheld that decision, stating it could not rule for Bryson because of lack of evidence:
We are sympathetic to plaintiff’s plight and find it deplorable that the conditions that led to his unjust confinement were permitted to continue for so long a time after the city was put on notice of the deficiencies in its forensic laboratory program. Nevertheless, we see no basis in the summary judgment record for holding the city liable in this case.
The court noted that, even if the city failed to properly train Gilchrist, she would have known that lying at trial and fabricating evidence was inappropriate. Complaints about Gilchrist’s work did not come to light until 1986, and the court agreed that the city could not have expected the misconduct. After city officials learned of defects in Bryson’s case in 2001, they fire Gilchrist. The court held that “the link between the city’s alleged failure to meaningfully supervise Ms. Gilchrist’s work after 1986 and the constitutional injury suffered by plaintiff is too attenuated to support a finding of municipal liability.”
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