Caldwell v. City and County of San Francisco, No. 16-15473 (9th Cir. 2018)Annotate this Case
Plaintiff filed suit against SFPD officials under 42 U.S.C. 1983, alleging that defendants fabricated evidence against him during a murder investigation. The district court granted defendants' motions for summary judgment. The Ninth Circuit held that because Caldwell rebutted any presumption of prosecutorial independence, he established a triable issue as to whether plaintiff fabricated evidence against him. Therefore, the panel reversed and remanded as to Crenshaw. The panel held that Gerrans and Crowly's investigation techniques were not so coercive that they rose to the level of fabricated evidence, and thus affirmed as to these two defendants.