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Knowles v. Hudson

United States District Court, N.D. Indiana, Hammond Division

September 11, 2019

ERIC KNOWLES, Plaintiff,
TRISTA HUDSON, et al., Defendants.



         This matter is before the court on the parties' motions to dismiss. (DE ## 16, 31, 35, 44.) For the reasons set forth below, the motions will be granted in part and denied in part.


         The following factual allegations are taken from plaintiff Eric Knowles' amended complaint (DE # 5) and are accepted as true for the purpose of resolving the pending motions. See Simpson v. Brown Cty., 860 F.3d 1001, 1009 (7th Cir. 2017).

         Knowles is the biological father of two children, C.E. and E.B., and the stepfather of two children, K.C. and E.C. (Id. at 3.) According to Knowles' amended complaint, his ex-wives and their current partners conspired with his stepchildren's father and his partner to fabricate claims that Knowles molested the four children, in order to prevail in their respective custody disputes against Knowles. (Id. at 1, 4-8.) Knowles alleges that, despite clear evidence that the allegations were false, defendant Prosecutor Trista Hudson and defendant Detective Janis Crafton charged and prosecuted Knowles on six counts of child molestation. Knowles alleges that defendants wrongfully coerced incriminating statements, fabricated evidence in the form of false testimony, and knowingly detained and prosecuted him without probable cause.

         The procedural history of the criminal proceedings is as follows. In June 2013, Knowles was arrested and charged with molesting E.B. (“June Charge”). (Id. at 14.) In July 2013, Knowles was charged with molesting K.C. and E.C. (Counts I-IV) and C.E. (Count V) (“July Charges”). (Id. at 17.)

         Knowles was tried on the June Charge in August 2015. (Id. at 19.) A jury returned a verdict of not guilty. (Id. at 20.) Knowles remained in jail pending trial on the remaining charges. (Id.)

         In June 2016, Knowles' trial on Counts I-IV of the July Charges began. (Id. at 21.) When Knowles' attorney cross-examined E.C., E.C. admitted that he lied when he claimed that Knowles molested him, and he explained that his father had instructed him to lie. (Id.) E.C. testified that he told Hudson and Crafton that he had lied the week before the trial began. (Id.) Crafton confirmed E.C.'s statement. (Id.) This information had not previously been disclosed to Knowles or his attorney. (Id.) The trial judge entered an order of acquittal on the four pending charges, and ordered that Knowles be released from jail in advance of his trial on Count V of the July Charges. (Id. at 24.) At the time of his release, Knowles had been in jail for more than three years. (Id.)

         The judge from the second trial reported Hudson to the state disciplinary commission. (Id. at 24.) The Indiana Supreme Court determined that Hudson committed misconduct by failing to disclose exculpatory evidence and by prosecuting a charge she knew was not supported by probable cause. (Id.) The Indiana Supreme Court suspended Hudson for 18 months. (Id. at 25.) Hudson's employment with Porter County was terminated following the second trial. (DE # 5-4 at 3.)

         In February 2017, while Count V was still pending, Crafton obtained a search warrant to search Knowles' computer for child pornography. (DE # 5 at 25.) While the search did not uncover child pornography, it revealed that on one occasion Knowles picked up his friend's child from elementary school, in violation of a protective order issued against Knowles due to the pending criminal charges. (Id.) Crafton recommended that Knowles be charged with misdemeanor invasion of privacy. (Id. at 26.) Knowles was arrested and held for one day prior to his release. (Id.) In March 2017, Knowles was charged with misdemeanor invasion of privacy. (Id.)

         In July 2017, the State dismissed the remaining child molestation charge (Count V). (Id. at 26.) In March 2018, the State dismissed the misdemeanor charge. (Id.)

         On September 21, 2018, Knowles filed the present suit, alleging nine counts against the defendants. In Counts I-V, Knowles alleges that defendants are liable under 42 U.S.C. § 1983 for violating his right to due process, his Fourth Amendment rights, and for failing to intervene in the violations of his constitutional rights. In Counts VI-VIII, Knowles alleges that defendants are liable under Indiana law for intentional infliction of emotional distress, malicious prosecution, and abuse of process. In Count IX, Knowles alleges an indemnification claim against the City of Portage.

         Before the court are four motions to dismiss. (DE ## 16, 31, 35, 44.) The motions are fully briefed and are ripe for ruling.


         Each of the parties have moved for dismissal pursuant to Federal Rule of Civil Procedure 12(b)(6), for failure to state a claim upon which relief may be granted. A judge reviewing a complaint pursuant to Rule 12(b)(6) must construe the allegations in the complaint in the light most favorable to the non-moving party, accept all well-pleaded facts as true, and draw all reasonable inferences in favor of the non-movant. United States ex rel. Berkowitz v. Automation Aids, Inc., 896 F.3d 834, 839 (7th Cir. 2018).

         Under the liberal notice-pleading requirements of the Federal Rules of Civil Procedure, the complaint need only contain “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed.R.Civ.P. 8(a)(2). “While the federal pleading standard is quite forgiving, . . . the complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ray v. City of Chicago, 629 F.3d 660, 662-63 (7th Cir. 2011); Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). A plaintiff must plead “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 129 S.Ct. 1937, 1949 (2009).

         To meet this standard, a complaint does not need detailed factual allegations, but it must go beyond providing “labels and conclusions” and “be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555. A complaint must give “enough details about the subject-matter of the case to present a story that holds together.” Swanson v. Citibank, N.A., 614 F.3d 400, 404 (7th Cir. 2010). Even if the truth of the facts alleged appears doubtful, and recovery remote or unlikely, the court cannot dismiss a complaint for failure to state a claim if, when the facts pleaded are taken as true, a plaintiff has “nudged their claims across the line from conceivable to plausible.” Twombly, 550 U.S. at 570.


         A. Trista Hudson's Motion to Dismiss

         Hudson argues that she is entitled to dismissal for four reasons: (1) she is entitled to absolute prosecutorial immunity; (2) Knowles failed to allege that she was personally involved before the charges were filed, or after his acquittal in the second trial; (3) Knowles' claims regarding the first and second trials are untimely; ...

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