Barnes v. City of New York
Conviction for drug possession did not preclude claim of deprivation of liberty for fabricating evidence of drug sale; plaintiff not required to show additional custody or conviction based on sale charge; Fourteenth Amendment claim based on fabricated evidence does not require custody or conviction; fabricated evidence claim requires: “that an (1) investigating official (2) fabricate[d] information (3) that is likely to influence a jury's verdict, (4) forward[ed] that information to prosecutors, and (5) the plaintiff suffe[red] a deprivation of life, liberty, or property as a re