960 F.3d 1094, 1099

Requiring proof that officer intended to deprive defendant of a fair trial to establish constitutional violation for failing to disclose exculpatory evidence. For arguments against this requirement, see, Avery, Paying for Silence: The Liability of Police Officers under Section 1983 for Suppressing Exculpatory Evidence, 13 Temple Political and Civil Rts. L Rev. 1 (2003).