Horn v. Stephenson, No. 19-2418 (2d Cir. 2021)
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Plaintiffs Horn and Jackson filed civil rights actions against the City of New Haven and law enforcement officials under 42 U.S.C. 1983. Plaintiffs each served more than 17 years in prison for a robbery and murder that they did not commit. Plaintiffs alleged that a police forensic examiner violated their due process rights under the Fourteenth Amendment by withholding exculpatory ballistics reports in contravention of Brady v. Maryland.
The Second Circuit affirmed the district court's denial of the examiner's motion to dismiss both actions, concluding that he cannot make out a defense of either qualified immunity or absolute immunity. In this case, the examiner is not entitled to qualified immunity where it was clearly established that a police forensic examiner, whether an analyst or technician fulfilling any of the roles associated with forensic analysis, in 1999 reasonably would have understood that he or she was required to turn over exculpatory information to the prosecutor. Furthermore, the examiner is not entitled to absolute immunity where, even if the court concluded that adjusting the margin of error in a General Rifling Characteristics (GRC) Report constituted prosecutorial advocacy, the complaint nowhere alleges that the examiner was asked or instructed to create a new GRC Report using a larger margin of error.
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