In June 1985, Nola Duncan and her brother David Rainey were murdered in Los Angeles, California. Police had no suspects until September 1985, when a jailhouse informant told the police that Harold Hall, in jail for an unrelated robbery, had confessed to the murders. The informant provided the police with handwritten notes that he had exchanged with Hall in which Hall admitted to the murder. Hall confessed to the murders after being interrogated for 17 hours without a break or access to an attorney. He later recanted his confession. No other evidence linked Hall to the murders. In April 1990, a jury convicted Hall of murdering Duncan and Rainey, and of raping Duncan, and he was sentenced to life without parole.
In April 1994, the convictions for Duncan’s rape and for Rainey’s murder were overturned on appeal because of insufficient evidence, but the conviction for Duncan’s murder was upheld. A few months later, the jailhouse informant recanted his statements and admitted to altering the notes to make Hall look guilty. The informant said he lied because he had hoped to receive leniency on a murder charge. Experts confirmed that the notes had been partly erased. Hall filed a state habeas corpus petition, and in 1995, the trial court overturned his conviction and granted him a new trial. The state appealed, and in 1996, the California Court of Appeals reversed the trial court’s decision, upholding Hall’s conviction. Hall continued to appeal his conviction, but was unsuccessful until September 2004, when the United States Court of Appeals for the Ninth Circuit granted Hall’s federal habeas petition and ordered a new trial. In August 2005, three days before Hall was scheduled for retrial, the prosecution announced that they were unable to proceed with the case and the charges were dropped.
Hall then sued the City of Los Angeles, the Los Angeles Police Department and several police officers, alleging the defendants had used false evidence against him. Two years later, Hall unsuccessfully moved to amend the complaint to include a coerced confession claim. A District Court eventually found that Hall's unamended complaint had not raised triable issues of fact to support his fabrication-of-evidence claim.
In September 2012, a split panel of 9th Circuit judges revived his lawsuit, reversing the District Court and allowing him to amend the complaint.
- Stephanie Denzel