Smalls v. Collins, No. 20-1099 (2d Cir. 2021)
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In tandem appeals, Plaintiffs Smalls and Daniel filed suit under 42 U.S.C. 1983 alleging that defendants deprived them of their rights to a fair trial by fabricating evidence against them. Daniel also asserted other claims under section 1983 and claims under 42 U.S.C. 1981 and sought equitable tolling of the statute of limitations applicable to some of his section 1983 claims. The district courts ultimately granted defendants' motions, concluding that Smalls and Daniel could not establish favorable terminations within the meaning of McDonough v. Smith, 139 S. Ct. 2149 (2019).
The Second Circuit concluded that the district courts erred in dismissing Smalls and Daniels' section 1983 fabricated-evidence claims and entering judgment for defendants. The court explained that McDonough's accrual rule does not import malicious prosecution's favorable-termination requirement onto section 1983 fair-trial claims; where the plaintiff asserts a section 1983 fair-trial claim based on fabricated evidence, all that is required is that the underlying criminal proceeding be terminated in such a manner that the lawsuit does not impugn an
ongoing prosecution or outstanding conviction; and this requirement may be satisfied where a criminal conviction has been invalidated or a criminal prosecution has been terminated in the criminal defendant's favor because, in such circumstances, there is no risk that a section 1983 plaintiff's claim will impugn an existing conviction or the basis for an ongoing prosecution. In this case, Smalls and Daniel's criminal proceedings terminated in their favor. Finally, the court also concluded that Daniel's section 1981 claims were properly dismissed, and Daniel's equitable tolling motion was properly denied. Accordingly, the court reversed with respect to the fair-trial claims, affirmed the dismissal of Daniel's other claims, and remanded for further proceedings.
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