Burge v. St. Tammany Parish

What This Case Is About

Burge v. St. Tammany Parish examines whether a sheriff can be held liable under § 1983 in his official capacity for depriving a criminal defendant of his constitutional right to a fair trial through the destruction or loss of evidence. The Fifth Circuit reversed the judgment against the sheriff, finding the evidence insufficient.

The Facts

In June 1991, Gerald Burge filed a § 1983 lawsuit against numerous defendants, including the sheriff of St. Tammany Parish, Louisiana. Burge claimed that law enforcement officials deprived him of his constitutional rights to due process and a fair trial by destroying or failing to preserve evidence relevant to the criminal charges against him.

The case had a long procedural history — filed in 1991, it wound through the courts for years. The district court eventually entered judgment against the sheriff of St. Tammany Parish (by the time of the appeal, Rodney Jack Strain held the office) in his official capacity, finding that the spoliation of evidence had deprived Burge of his right to a fair trial.

Burge also asserted a state-law tort claim against the sheriff for spoliation of evidence. The district court dismissed that claim.

What the Court Decided

The Fifth Circuit reversed the judgment against Sheriff Strain on the § 1983 claim and affirmed the dismissal of Burge’s state-law spoliation claim.

On the § 1983 claim, the court found that the evidence was insufficient to establish that the sheriff’s office had engaged in conduct that deprived Burge of his right to a fair trial. Under the Supreme Court’s framework in Arizona v. Youngblood and Brady v. Maryland, the government violates due process when it destroys evidence that is both material and exculpatory, or when it acts in bad faith in failing to preserve potentially useful evidence. The court found that Burge did not meet this standard.

For the official-capacity claim against the sheriff, the court applied the Monell framework. A suit against a sheriff in his official capacity is effectively a suit against the governmental entity he represents. Liability requires showing that an official policy or custom was the “moving force” behind the constitutional violation. The evidence did not support such a finding.

On the state-law claim, the court affirmed the dismissal, finding that Burge failed to establish the elements of a spoliation tort under Louisiana law.

Why This Case Matters for Your § 1983 Case

Burge v. St. Tammany Parish is relevant for several reasons:

• Evidence preservation obligations are limited. The government’s duty to preserve evidence is not absolute. Under Youngblood, bad faith must be shown when the evidence is merely “potentially useful” rather than materially exculpatory.

• Official-capacity suits are entity suits. A suit against a sheriff in his official capacity is really a suit against the county or parish. This means you must satisfy Monell requirements — identifying an official policy or custom that caused the violation.

• Due process fair-trial claims require strong evidence. Allegations of evidence destruction must be supported by concrete proof of materiality and, in many cases, bad faith. Generalized claims that evidence was lost or mishandled may not suffice.

Key Takeaway

If your case involves government officials destroying or losing evidence, Burge v. St. Tammany Parish warns that you must establish either that the evidence was materially exculpatory under Brady or that the government acted in bad faith under Youngblood. Official-capacity claims against sheriffs require satisfying the demanding Monell framework for municipal liability.