Dist. Ct. erred in dismissing on standing grounds plaintiff's section 1983 action, alleging that defendants (Sheriff and his deputies) concealed and/or destroyed evidence that decedent's estate could have used to help it pursue claims against putative murderers of decedent. While state court denied plaintiff's (relative of decedent) request to replace existing administrator of estate, record also showed that estate assigned to plaintiff whatever interest it had in instant lawsuit. As such, because of estate's assignment, plaintiff could pursue any damages claims against tortfeasors, and federal law permits assignee to sue on estate's behalf. Ct. of Appeals also observed that defendants did not deny him access to state courts and expressed doubt as to whether any alleged spoliation of evidence claim could supply basis for independent federal lawsuit under denial of access to courts theory at issue in instant lawsuit.
Federal 7th Circuit Court
Civil Court
Standing