Police role in wrongful charges

1. Whether a district court may dismiss a pro se § 1983 complaint with prejudice at the pre-service screening stage under 28 U.S.C. § 1915(e)(2) for failure to plead facts that are exclusively within the State’s possession, thereby denying the plaintiff any opportunity for discovery — a rule that conflicts with Leatherman v. Tarrant County, 507 U.S. 163 (1993), and with the decisions of the Second, Seventh, and Ninth Circuits, which hold that civil-rights plaintiffs cannot be required to plead evidence they cannot access without discovery. 2. Whether the independent-intermediary doctrine bars a Fourth Amendment malicious-prosecution claim when the plaintiff alleges that investigators withheld exculpatory evidence, ignored readily available witnesses, and presented a misleading narrative to the prosecutor — conduct that, under this Court’s decisions in Malley v. Briggs, Kalina v. Fletcher, Buckley v. Fitzsimmons, and Manuel v. City of Joliet, defeats the presumption of independent judgment and removes prosecutorial immunity for investigative acts. 3. Whether a prosecutor’s offer of a reduced misdemeanor plea deal in a case charged as a felony may be considered evidence of a lack of probable cause when evaluating a § 1983 claim alleging that the charging decision was tainted by omissions and misrepresentations.