McDonough v. Smith

Edward McDonough, the former District Attorney of Rensselaer County, New York, was prosecuted in 2012 for allegedly forging absentee ballots in a 2009 primary election. He was acquitted after trial. McDonough then sued state police investigator Todd Smith and others under 42 U.S.C. § 1983, asserting that they fabricated evidence and subjected him to malicious prosecution. The district court and the Second Circuit dismissed the fabrication-of-evidence claim as untimely, ruling that the statute of limitations began to run when the evidence was used against him. The U.S. Supreme Court reversed on June 20, 2019, holding that a fabrication-of-evidence claim accrues only when the underlying criminal proceedings terminate in the plaintiff's favor, similar to the rule for malicious prosecution claims.

The U.S. Supreme Court reversed the Second Circuit in a 6-3 decision, holding that a fabrication-of-evidence claim under Section 1983 does not accrue until the criminal proceedings against the accused have terminated favorably.

Whether the statute of limitations for a Section 1983 fabrication-of-evidence claim begins to run when the fabricated evidence is used against the accused in a criminal proceeding, or only when the criminal proceeding ends in the accused's favor.

The decision resolved a circuit split and ensured that individuals can seek redress for fabrication of evidence without being forced to file premature civil suits that could interfere with ongoing criminal defenses. It reinforced procedural protections by aligning the accrual rule with malicious prosecution, thereby strengthening constitutional safeguards against wrongful convictions and clarifying the timeline for evidence-fabrication claims.