10/20/2026
Man exonerated after 27 years files federal lawsuit alleging fabricated evidence and suppressed exculpatory material
Proceeding: Dillard v. City of Elkhart et al., No. 3:26-cv-01495 (N.D. Ind., filed Oct. 14, 2026).
Court: United States District Court for the Northern District of Indiana.
27 years Wrongfully imprisoned
Exonerated February 23, 2026; federal civil-rights complaint filed October 14
In February 2026, following post-conviction proceedings brought by Notre Dame Law School's Exoneration Justice Clinic, a special prosecutor agreed that Dillard's due-process rights had been violated through suppression of material exculpatory evidence.
His conviction was vacated, the charges were dismissed, and he was released.
The new development
On October 14, Dillard filed a federal civil-rights lawsuit against the City of Elkhart, the State of Indiana, and several former officials and other defendants.
The complaint alleges misconduct involving fabricated evidence, withheld exculpatory information, and witness-related improprieties.
The federal docket confirms the filing under 42 U.S.C. § 1983.
Notre Dame's earlier reinvestigation identified several categories of potentially decisive evidence: undisclosed information implicating alternative suspects, police internal-affairs material concerning Detective Stephen Rezutko's improper relationships with informants, and evidence of benefits offered to prosecution witnesses.
Practical significance for wrongful-conviction advocacy
This case illustrates the importance of investigating impeachment evidence that was never presented to the defense.
The controlling constitutional authorities include Brady v. Maryland, 373 U.S. 83 (1963), Giglio v. United States, 405 U.S. 150 (1972), and Kyles v. Whitley, 514 U.S. 419 (1995).
A comprehensive post-conviction investigation should identify whether police possessed favorable material, whether witnesses received undisclosed inducements, and whether misconduct involving an investigating officer affected other prosecutions.
Authority status: The vacatur and dismissal of Dillard's conviction are established procedural outcomes. The new federal complaint's allegations have not been adjudicated, and no civil-liability finding should be inferred. Research purposes only