In Rentas v. Ruffin, 816 F.3d 214 (2d Cir. 2016), the U.S. Court of Appeals for the Second Circuit took the highly unusual step of ordering a new trial in light of the district court’s erroneous exclusion of evidence in a case brought by a Rikers prison inmate alleging he was assaulted by corrections officers, who then made false statements leading to the inmate’s conviction. The case provides a reminder as to the complexities of civil rights cases under Section 1983, particularly involving claims of malicious prosecution and right to fair trial.
‘Rentas’: the Facts
On July 12, 2007, Axel Rentas was serving a misdemeanor sentence on Rikers Island, three weeks away from release. Rentas got into an altercation with a number of correction officers, apparently concerning an order to move to a new bed. Everything about the altercation was hotly disputed: “who initiated the fight, the degree to which Rentas resisted, and whether he was injured before or after the Rikers staff placed him in handcuffs.”
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