It is rare that people who are convicted and imprisoned for crimes when they are actually innocent are exonerated. Currently there are only 12 people who have been exonerated in the past decade listed on the National Registry of Exonerees. Thirty five states and the District of Columbia provide for compensation to an exoneree who served time in prison before exoneration. The potential payment in New Jersey is $50,000 per year. If an exoneree successfully brings a claim for monetary damages against law enforcement personnel or their employer for violations of constitutional rights that result in a conviction, the award is subject to a set off of the money that was previously paid by the state. Because of substantial hurdles and problems of proof, and the defense of qualified immunity available to the police, public officials and public employers, there are few successful claims. Court decisions have shielded wrongdoers from liability.