Armstrong v. Daily’s Empirical Analysis
786 F.3d 529 · 2015
Citation profile
10 federal appellate ·
Relationships
Applies 28 U.S.C. § 1915A · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Bell Atlantic Corp. v. Twombly · Ashcroft v. Iqbal · Brady v. State of Maryland · Monell v. Department of Social Services of City of New York · Harlow v. Fitzgerald
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] duty to refrain from bad-faith destruction flows necessarily, and obviously, from [ Brady's ] familiar holding that suppression of material exculpatory evidence violates due process.”
2 later decisions quote this exact passage · from the concurrence“1. Is a Trial Needed for a Constitutional Violation? The constitutional violation that Armstrong asserts is the deprivation of his liberty without due process of law, as the result of the destruction of evidence by a state actor. See Zahrey v. Coffey, 221 F.3d 342, 349 (2d Cir. 2000) (defining the right at issue as “the right not to be deprived of liberty as a result of the fabrication of evidence by a government officer acting in an investigating capacity”). Though the most common liberty deprivation cases are based on post-trial incarceration after a wrongful conviction, the essential elements of this constitutional claim are more general and not limited to wrongful convictions. See Fields v. Wharrie, 740 F.3d 1107, 1112 (7th Cir. 2014) (“[T]he fabrication of evidence harmed the defendant before and not just during the trial, because it was used to help indict him.”). Armstrong’s claim therefore has two essential elements: (1) the defendant destroyed exculpatory evidence... (2) that caused a deprivation of the plaintiffs liberty.”
1 later decision quote this exact passage · from the concurrence“[t]he claim in Albright was only that the plaintiff had been prosecuted without probable cause.... [Tjhere was no claim that a law enforcement official had acted in bad faith to undermine the reliability of a trial, such as by manufacturing false evidence, arranging for perjured testimony, or destroying exculpatory evidence'.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.