Police use of fabricated evidence to elicit a confession creates an independent cause of action sounding in due process, a federal appeals court held April 24 in reinstating a suit by a man jailed for more than two decades on a wrongful murder conviction.

The U.S. Court of Appeals for the Third Circuit ruled in Halsey v. Pfeiffer that a district judge mistakenly found that a defendant can seek redress for fabrication of evidence only as a malicious prosecution claim under the Fourth Amendment.

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