King v. Graham

PAUL W. GREEN, J.,

dissenting.

It is frequently said that actions for malicious prosecution are not favored in the law. This aphorism is far too vague to serve as an analytical tool. As with any other cause of action, if the elements of malicious prosecution are proved, liability is established. What is distinctive about malicious prosecution is that there is little room for error in applying the law. Even a small departure from the exact prerequisites for liability may threaten the delicate balance between protecting against wrongful prosecution and encouraging reporting of criminal conduct.

Browing-Ferris Indus., Inc. v. Lieck, 881 S.W.2d 288, 291 (Tex.1994) (citations omitted). We are thus admonished to exercise extreme care when applying the facts to the multiple legal elements of malicious prosecution cases. The “delicate balance” can teeter on even a single element of the cause of action and, depending on whether a court strictly applies the law, an already bad situation can get even worse. As grievous as it is for an innocent person to be wrongly accused of a crime, that harm is not fairly compensated by holding the accuser who acted in good faith liable for wrongful prosecution. The legal protection afforded the good faith accuser is in the requirement that we hold the plaintiff to a strict burden of proof. Otherwise, overriding sympathy favoring the innocent plaintiff may lead to an unjust jury verdict. That is what I believe has happened in this case.

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As a matter of good social policy, most would agree citizens should not be discouraged from reporting what is believed to be criminal conduct. But there are risks in doing so. One of the risks is that they will be sued by the subject of the criminal report. When the criminal reporting is *613reckless or malicious, the law provides a remedy. But what about cases where the complainant is acting in good faith, although misguided or misinformed? How does society weigh the social value of reporting crime against the damage done to the innocent target of a misinformed criminal complaint? The supreme court says these competing interests are balanced through careful definition of the elements of the malicious prosecution cause of action. See id.

One of the basic elements of any tort action is causation. The same is true with malicious prosecution cases. Id. at 292. But the supreme court has adopted the view that “initiation and procurement,” rather than the more general concept of causation, is better suited to malicious prosecution cases. Id. at 293. That is to say, the question is not whether the defendant “caused” the criminal proceedings, but whether the defendant “initiated” or “procured” the prosecution. Id. In this case, the question is whether King and his co-defendants (collectively referred to as “King”), “procured” the indictment against Graham and Wren.

The concept of procurement is essentially the same as the cause-in-fact element of proximate cause, but it does not include the foreseeability component of proximate cause. Id. at 292.

A person procures a criminal prosecution if his actions were enough to cause the prosecution, and but for his actions the prosecution would not have occurred. A person does not procure a criminal prosecution when the decision whether to prosecute is left to the discretion of another, including a law enforcement official or the grand jury, unless the person provides information which he knows is false.

Id. at 293. Thus, when a prosecutor exercises discretion in deciding whether to prosecute, a malicious prosecution defendant cannot have procured the prosecution unless the defendant provided information he knew to be false and the false information was a determining factor in the decision to prosecute. See id. at 293-94. In other words, any false information must have been relied upon in some way by the person making the decision to prosecute; otherwise, there is no procurement.

There is no procurement in this case. Even assuming King’s complaint letter to the district attorney purposely omitted information or contained information known to be false, the evidence clearly demonstrates the district attorney did not base his decision to prosecute on any of the allegedly false or omitted information.

Graham and Wren contend the complaint letter King sent to District Attorney Sutton falsely asserted that hunters had been booked by SSI during the final week of October and that Graham and Wren had not reserved any animals. Moreover, they argue King’s failure to disclose the existence of 99 phone calls Graham and Wren had made to SSI contributed to their prosecution. They also say the price sheets attached to the letter agreement between the parties should not have been omitted from the complaint letter, that Hugo Ber-langa’s name should not have been shown as a SSI shareholder, and that the corporate name of SSI should not have been used because it had not been successfully filed with the Secretary of State.

However, the evidence is undisputed that any inaccuracies or omissions in King’s letter were not a determining factor in DA Sutton’s decision to prosecute. Both Sutton and Deputy Sheriff Alford testified the omission of the price sheet, the use of Berlanga’s name, and the use of SSI’s corporate name played no part in the decision to investigate and prosecute. And regarding the statement that hunts had been booked, Sutton said the issue was whether money had been taken for a par*614ticular purpose and not applied to that purpose, not whether any hunters had been booked.

In light of Sutton and Alford’s testimony, it cannot reasonably be concluded the prosecution would not have occurred but for the allegedly false statements in King’s letter. To hold otherwise is to say that King is liable regardless of whether the complaint letter contained knowingly false information. The nexus between conduct and harm is missing and, consequently, Graham and Wren’s case must fail. Moreover, by upholding the jury verdict, the majority permits the jury to find, in the absence of contrary evidence, the exact opposite of Sutton and Alford’s testimony. This is clearly wrong.

In short, the jury’s verdict is not supported by the evidence. And by failing to pay strict attention to the “exact prerequisites for liability,” the majority has fallen into the error warned about in Lieck. Consequently, I dissent.