Jeffrey Vantlin, et al. v. William Hurt, et al.

After a state medical examiner’s homicide conclusion and resulting investigations, officers interrogated three siblings. Two confessed to the involvement of all three siblings and their foster brother in the killing. The confessions matched the physical evidence, with the exception of the body location. In criminal proceedings, one confession was admitted and other was suppressed. At summary judgment, all parties cited the undoctored, complete interrogation videos. In affirming the district court’s denial of summary judgment on qualified immunity on the Fourth and Fifth Amendment claims, the Seventh Circuit’s decision raises important issues of law:

1. Whether the Seventh Circuit properly concluded it did not have jurisdiction to review undoctored, complete videotaped interrogations de novo and in the light presented by the videotape to determine whether the confessions were coerced under the Fifth Amendment, despite reviewing such videos and reversing the district court’s denial of qualified immunity under the Fourteenth Amendment by finding the officers’ actions did not “shock the conscience”?

2. Whether probable cause is not established, because an officer cannot rely on a medical examiner’s homicide conclusion and the reliability of a confession is “conclusively undermined” by one aspect of the confession (i.e., the location of the body) not matching the physical evidence when other aspects do?

3. Whether the Seventh Circuit has created a new standard for determining whether an officer’s “verbal