Chapdelaine v. Desjardin

The United States Court of Appeals for the Second Circuit, in *Chapdelaine v. Desjardin*, recently clarified critical aspects of civil rights litigation under 42 U.S.C. § 1983, particularly concerning malicious prosecution claims. The July 2, 2026, decision affirmed that the dismissal of criminal charges contingent upon the completion of a diversionary program does not constitute a "favorable termination" for the purpose of a Fourth Amendment malicious prosecution claim, even after the Supreme Court's ruling in *Thompson v. Clark*. The court also upheld the district court's discretion in excluding evidence of internal police discipline under Federal Rule of Evidence 403 and reinforced the stringent preservation requirements for post-verdict motions under Federal Rule of Civil Procedure 50. This ruling provides crucial guidance for practitioners navigating civil rights actions against law enforcement, especially regarding the nuanced interpretation of "favorable termination" and evidentiary admissibility.

The landscape of civil rights litigation, particularly claims brought under 42 U.S.C. § 1983, continues to evolve with significant appellate court pronouncements. A recent decision from the United States Court of Appeals for the Second Circuit, *Chapdelaine v. Desjardin*, issued on July 2, 2026, offers timely and critical clarification on several recurring issues faced by practitioners in this complex area. The case, arising from an arrest by Connecticut State Troopers, addresses the intricate requirements for establishing a malicious prosecution claim, the admissibility of internal police disciplinary records, and the procedural hurdles for challenging jury verdicts.

At its core, *Chapdelaine v. Desjardin* grappled with the interpretation of "favorable termination" in malicious prosecution claims following the Supreme Court's landmark decision in *Thompson v. Clark*. The Second Circuit's ruling underscores that not every non-conviction disposition automatically satisfies this element, particularly when a criminal case is resolved through a diversionary program. This article will delve into the factual and legal underpinnings of the decision, analyze its implications for attorneys representing both plaintiffs and defendants in civil rights actions, and highlight key takeaways for navigating similar disputes in the future.

Claims for malicious prosecution under 42 U.S.C. § 1983 provide a federal remedy for individuals whose Fourth Amendment rights have been violated by state actors. A central element of such a claim is that the underlying criminal proceeding must have terminated in the plaintiff's favor. Historically, courts in the Second Circuit and elsewhere often required an "affirmative indication of innocence" to satisfy this favorable termination element. This standard presented a significant hurdle for plaintiffs, as many non-conviction dispositions, such as dismissals for administrative reasons or plea bargains, did not necessarily imply innocence.

The legal framework for "favorable termination" underwent a significant shift with the Supreme Court's decision in *Thompson v. Clark*, 142 S. Ct. 784 (2022). In *Thompson*, the Supreme Court rejected the "affirmative indication of innocence" requirement, holding instead that a plaintiff need only show that the criminal prosecution ended without a conviction. However, *Thompson* did not fully delineate what types of non-conviction dispositions would qualify, leaving room for interpretation by lower courts regarding dispositions that reflect a compromise or are not indicative of the merits of the charges. This ambiguity set the stage for cases like *Chapdelaine v. Desjardin* to further define the boundaries of this crucial element.

The *Chapdelaine* case originated from the 2018 arrest of Darlene Chapdelaine by Connecticut State Troopers Robert L. Desjardin and Jason N. Deojay, leading to charges of assault, disorderly conduct, and resisting arrest. Following her completion of a one-day supervised diversionary program, the state criminal charges against Ms. Chapdelaine were dismissed. She subsequently filed a federal civil rights lawsuit, alleging, among other claims, malicious prosecution and excessive force.

The Second Circuit, affirming the district court, held that the dismissal of charges conditioned on the completion of a diversionary program did not constitute a "favorable termination" for the purposes of a § 1983 malicious prosecution claim. The court reasoned that such a dismissal, arising from a court-ordered compromise with an explained, negotiated basis, was akin to compromise dispositions previously deemed not to be favorable terminations, as discussed in cases like *Carruthers v. Colton*, 518 F. App'x 24 (2d Cir. 2013). The panel emphasized that while *Thompson v. Clark* eliminated the "affirmative indication of innocence" standard, it did not abolish the favorable termination requirement itself or its underlying purposes, which include avoiding parallel litigation and preventing collateral attacks on criminal adjudications.

Beyond the malicious prosecution claim, the Second Circuit also addressed evidentiary issues and post-verdict challenges. The court found no abuse of discretion in the district court's decision to exclude evidence of Trooper Desjardin's internal police discipline and most internal affairs findings under Federal Rule of Evidence 403. Rule 403 allows for the exclusion of relevant evidence if its probative value is substantially outweighed by a danger of unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence. This aspect of the ruling reinforces the broad discretion afforded to trial courts in managing evidence, particularly sensitive internal police records.

Finally, the appellate court affirmed the district court's denial of Chapdelaine's post-verdict request for judgment as a matter of law, thereby upholding the jury's verdict rejecting her excessive force claims. This implicitly underscores the rigorous preservation requirements for motions made under Federal Rule of Civil Procedure 50, which allows a party to seek judgment as a matter of law after a jury verdict. Practitioners must ensure that arguments for such motions are adequately preserved throughout the trial proceedings to succeed on appeal.

The Second Circuit's decision in *Chapdelaine v. Desjardin* provides crucial clarity for attorneys engaged in civil rights litigation. For plaintiffs, it serves as a cautionary tale: not all non-conviction outcomes will satisfy the favorable termination element for malicious prosecution claims, particularly those involving diversionary programs that imply a negotiated resolution rather than an outright vindication of innocence. Practitioners must carefully scrutinize the nature of the criminal disposition and be prepared to argue why it reflects a termination on the merits, rather than a compromise.

For defendants, the ruling reinforces the strength of arguments against the admissibility of internal disciplinary records under Federal Rule of Evidence 403, highlighting the importance of demonstrating the potential for unfair prejudice or confusion. Furthermore, the affirmation of the district court's handling of the Rule 50 motion underscores the necessity of meticulous procedural compliance and robust argument preservation throughout trial. As civil rights cases continue to be a significant area of litigation, understanding these nuances, especially in the wake of *Thompson v. Clark*, will be paramount for effective advocacy in the Second Circuit and potentially beyond.