Can a claim of after-the-fact false reporting, by itself, fail to state a claim upon which relief can be granted?

The claim of after-the-fact false reporting does nothing to change the analysis. "[P]reparing a false report about an incident after it occurred cannot subject that individual to liability for the force used during the incident." Sim v. Duran, No. 1:16-CV-01051-SAB (PC), 2017 WL 5972739, at *5 (E.D. Cal. Dec. 1, 2017) ("A complaint alleging that an officer filed a false report, by itself, fails to state a claim upon which relief can be granted." (quotation marks omitted)).