The Eleventh Circuit Court of Appeals upheld a $7 million verdict against the city of Miramar, FL, sheriff's office and law enforcement officers who coerced a confession from a teenager with a low IQ.
Anthony Caravella, who spent 26 years behind bars, is close to celebrating his fifth year of freedom after being exonerated of a 1983 rape and murder conviction in March 2010.
In his suit, Caravella alleged that officers William Mantesta and George Pierson coerced his confessions, concealed evidence, fabricated evidence and caused intentional emotional distress.
At the age of 15 with an IQ of 67, Caravella was arrested by Miramar officers after he failed to appear in court for a bicycle theft charge.
Prior to this incident, Caravella served as an informant for the same officers who were involved in his interrogation.
The officers coerced Caravella to confess to the murder and rape in multiple statements.
He was also forced to participate in a polygraph test over a four-day period. Following these events, he was convicted and sentenced to life in prison.
The 1983 conviction was re-examined after a series of Sun Sentinel stories initiated by his younger brother, Larry Dunlap.
Seventeen years later in 2001, Assistant Public Defender Diane Cuddihy requested DNA testing of evidence collected from the victim’s body. DNA testing gained prominence in criminal trials in 1987.
It took eight years to receive the results from samples collected. However, it was conclusive that DNA was linked to someone other than Caravella.
During trial, the defendants moved to dismiss the case, arguing that the expired statute of limitations barred most of the Caravella's claims.
However, the judge ruled the case would proceed because, under the Florida continuing tort doctrine and the delayed discovery doctrine, the limitations period runs until the tortious conduct ceases. Hence, the tortious conduct ended when Caravella was released from prison.
A federal jury in March 2013 found the former Miramar police officers liable for framing Caravella, stating that the officers while acting as members of the City of Miramar Police Department violated his constitutional rights, coerced him to confess and withheld evidence that would have prevented his conviction.
Following the 2013 verdict, Caravella commented, “I have to say I finally believe in the system,” adding “I was worried. I was afraid they were going to get away with it.”
125 Recent Exonerations
The National Register of Exonerations reports a record 125 exonerations in 2014 alone. Twenty-two of the 125 stemmed from DNA evidence. Most recent information cites the major contributing factor for exoneration is perjury and false accusations, followed by official misconduct.
In a similar case, The National Trial Lawyers reported in March 2014 about a father who was wrongly convicted for his daughter’s murder. In this case, Jerry Hobbs was exonerated in 2010 after DNA evidence confirmed a match to a convicted killer. Hobbs was awarded $7.75 million.
Barbara Heyer, Caravella’s attorney says she will investigate all options including whether the city has insurance to cover the cost.
This case is Spadaro v. City of Miramar, etc., et al., Case No. 13-15028, U.S. Court of Appeals, Eleventh Circuit.