The following excerpt is from Pellerin v. Nev. Cnty., No. CIV S 12-665 KJM CKD (E.D. Cal. 2013):
Plaintiff claims defendants' actions and inactions violated his Fourth Amendment rights but he has not cited to any case supporting his claim that the mishandling of exculpatory evidence constitutes such a violation in the absence of a claim that the failure to produce exculpatory evidence after his arrest unreasonably prolonged his detention or contributed to his conviction. See Russo v. City of Bridgeport, 479 F.3d 196, 210 (2d Cir. 2007) (holding that officers who viewed videotape of crime and falsely represented to defendant that it was
Page 11
inculpatory when, in fact, it was exculpatory, could be sued for actively hiding exculpatory evidence resulting in unreasonably prolonged detention in violation of Fourth Amendment); Taylor v. Waters, 81 F.3d 429, 437 (4th Cir. 1996) ("[A]lthough open communication between investigators and prosecutors should be encouraged, the failure of an officer to disclose exculpatory evidence after a determination of probable cause has been made by a neutral detached magistrate does not render the continuing pretrial seizure of a criminal suspect unreasonable under the Fourth Amendment.").
D. Manipulation of Evidence Claim
The above passage should not be considered legal advice. Reliable answers to complex legal questions require comprehensive research memos. To learn more visit www.alexi.com.