Patterson v. Burge
United States District Court for the Northern District of Illinois
328 F. Supp. 2d 878 (2004)
Patterson (plaintiff) alleged that Chicago police detectives (defendants) investigating a 1986 double murder coerced false testimony, threatened suspects, ignored evidence pointing to other perpetrators, and tortured Patterson and his co-defendant into confessing, leading to Patterson's wrongful conviction and 13 years on death row before Governor Ryan pardoned him in 2003; Patterson sued the officers under § 1983 for violating his due process rights by fabricating and coercing his confession, hiding that fact from prosecutors and his own defense, and suppressing exculpatory evidence, and the defendants moved to dismiss.
Whether, to state a due-process claim under 42 U.S.C. § 1983, a plaintiff must allege that defendants obstructed justice or withheld evidence necessary to ensure a fair and impartial trial.