Lester v. Roberts
Court finds probable cause for prosecution without relying on presumption of probable cause based on grand jury indictment; in dictum, however, court notes plaintiff’s claim that presumption should have been overcome by evidence that prosecution failed to disclose exculpatory evidence to grand jury; court, in dictum, distinguishes between failure to disclose exculpatory evidence and presenting false evidence, suggesting that only the latter would overcome presumption, stating that Constitution does not require prosecutors to present any exculpatory evidence to grand jury.