Armstrong v. Daily

Dist. Ct. did not err in denying defendants-prosecutor and lab technicians’ motion to dismiss on grounds of qualified immunity plaintiff’s section 1983 action alleging that defendants deprived him of due process by destroying exculpatory DNA evidence in order to frame plaintiff on murder charge. Instant action was not barred under Parratt doctrine, even though state tort remedies existed for same wrong, where instant claim concerned right essential to fundamental fairness of criminal trial. Moreover, defendants were not entitled to qualified immunity since at time of original investigation case law had established that bad-faith destruction of exculpatory evidence would violate suspect’s due process rights. Fact that plaintiff was not re-tried on murder charge after destruction of exculpatory evidence did not require different result. (Partial dissent filed.)