Case Explained: ERNEST N. FINLEY, JR. JENNIFER M. REAVES v. STEVEN L. REED in both his official and individual capacities, et al THOMAS ALBRITTON CYNTHIA RAULSTON BYRON BUTLER

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-17 Docket: 2:23-cv-00464-KKD-PBM The Eleventh Circuit affirmed the district court’s grant of summary judgment in favor of Alabama Ethics Commission officials Byron Butler, Cynthia Raulston, and Thomas Albritton against police chiefs Ernest Finley and Jennifer Reaves. The plaintiffs alleged that the defendants violated their due process rights by fabricating evidence during an ethics investigation regarding a firearms qualification incident. The court held that the defendants were entitled to qualified immunity because no reasonable jury could find that they acted with bad faith or fabricated evidence. Applying the standard that fabrication requires proof of intent to link the accused to a crime, the court found that the officials’ actions were based on good-faith beliefs supported by contemporaneous records. Specifically, the court noted that Department policy 2.311 remained active in the internal computer system and was cited in official communications and disciplinary forms at the time of the investigation, despite a purported rescission by policy 3.2.4. The officials’ reliance on City Attorney Stacy Bellinger’s representations regarding the policies and their mistaken belief that a memorandum attached the relevant policy were deemed honest mistakes rather than fabrication. Furthermore, the court found no evidence of bad faith in the presentation of a disciplinary form for Officer Richardson, as a similar form existed for another officer, validating the officials’ assertion that an officer had been disciplined under the active policy. As a result, the plaintiffs’ federal claims failed, and the district court’s decision to decline supplemental jurisdiction over state-law claims stands. The judgment for the defendants is affirmed, leaving them immune from liability for their conduct during the investigation. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.