An Illinois Supreme Court opinion released Thursday reverses the 4th Appellate Court’s dismissal of a claim alleging conspiracy and malicious prosecution against three former Normal Police officers in a 1993 murder case.
The Illinois Supreme Court sided with Alan Beaman, the man who spent years in prison after being wrongly convicted for murder in the death of Jennifer Lockmiller.
Beaman claimed the 4th District Appellate Court did not accurately judge his claim of malicious prosecution. The Illinois Supreme Court agreed.
Justice Thomas Kilbride’s opinion said the appellate court needs to consider whether the defendants simply played a significant role in Beaman’s prosecution.
If the appellate court finds that to be true, Beaman’s claim will move forward in the process.
Normal Corporation Counsel Brian Day said the town's attorneys are currently analyzing the implication of the court's decision.
"It's important to note here that the court only discussed and clarified a technical legal standard to apply, and it didn't in any way suggest that the plaintiff's claim has any merit," Day said.
Beaman was released in 2008. He filed this civil suit in 2014, alleging former Normal Police officers Tim Freesmeyer, Dave Warner, Frank Zayas and the Town of Normal, by extension, of alleged malicious prosecution, intentional infliction of emotional distress, and civil conspiracy. Two additional claims were filed against the town asking for money from damages.
The circuit court found that the defendants “did not exert an unusual influence on the prosecutors” leading to Beaman’s prosecution. The court then dismissed the other four claims saying they were dependent on the malicious prosecution claim.
In 2017, the 4th District Appellate Court affirmed the lower court’s decision.
In his Illinois Supreme Court appeal, Beaman challenged the circuit court’s initial summary judgement.
The Illinois Supreme Court says a plaintiff must prove five elements for malicious prosecution to be present:
- Commencement or continuance of an original criminal or civil judicial proceeding by the defendant
- The termination of the proceeding in favor of the plaintiff
- The absence of probable cause for such proceeding
- The presence of malice
- Damages resulting to the plaintiff
The circuit court said Beaman could not prove the first four elements. The appellate court agreed.
But Beaman argued the appellate court applied the wrong standard to “commencement or continuance.” He provided three tests that can be used
- The significant role test
- The advice and cooperation test
- The pressure, influence, or misstatement test
He said the court relied too heavy on the third test. The Illinois Supreme Court agreed.
This isn’t the Illinois Supreme Court ruling in favor of Beaman’s claim of malicious prosecution. Instead, it's saying the appellate court needs to rethink its decision of upholding the circuit court’s ruling. From here Beaman, the officers, and the town’s fate is in the hands of the appellate court yet again.
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