The United States Court of Appeals for the Second Circuit recently upheld a lower court's decision to dismiss claims brought by Darlene Chapdelaine against two Connecticut state troopers, Robert L. Desjardin and Jason N. Deojay. The court ruled that Chapdelaine's arrest did not violate state or federal law, and her claims for malicious prosecution and excessive force were not substantiated. This ruling affects individuals who may seek to challenge police conduct and highlights the complexities surrounding claims of malicious prosecution.
The case, Chapdelaine v. Desjardin, docket number 24-2535, stems from an incident on Thanksgiving Day 2018, when Chapdelaine was arrested for allegedly assaulting an elderly victim, disorderly conduct, and resisting arrest. The court's decision, issued on July 2, 2026, affirmed the lower court's findings after a jury trial that ruled in favor of the defendants.
Background
Darlene Chapdelaine, the plaintiff, lived with Bruce Serwecki, a 75-year-old man, at her home in Dayville, Connecticut. On November 22, 2018, Serwecki's granddaughter called 911, reporting that Chapdelaine was intoxicated and had assaulted Serwecki. Responding officers, Desjardin and Deojay, arrived at the scene and subsequently arrested Chapdelaine.
Following her arrest, Chapdelaine filed a lawsuit against the troopers, alleging malicious prosecution and excessive force. The case went through various stages in the District Court for Connecticut, where the court granted summary judgment on some claims and allowed others to proceed to trial. Ultimately, a jury found in favor of the troopers, leading to Chapdelaine's appeal.
The Ruling
The Second Circuit Court upheld the lower court's decisions, stating that the dismissal of Chapdelaine's criminal charges was not a favorable termination for her malicious prosecution claim. The court noted, "The dismissal of Chapdelaine's criminal charges was not a favorable termination for purposes of a malicious prosecution claim." The judges involved in the ruling were Chin, Lee, and Robinson.
Additionally, the court affirmed the exclusion of evidence relating to Desjardin's disciplinary record, which Chapdelaine sought to introduce during the trial. The judges found no error or abuse of discretion in the district court's decision to exclude this evidence, emphasizing that it could mislead the jury regarding the standard for excessive force.
Impact
This ruling has significant implications for future cases involving claims of malicious prosecution and excessive force against law enforcement. It clarifies that a dismissal of charges resulting from a diversionary program does not necessarily equate to a favorable termination in malicious prosecution claims. This decision reinforces the need for plaintiffs to demonstrate clear evidence of wrongful conduct by law enforcement to succeed in such claims.
The court's ruling may also impact how future cases are litigated, particularly regarding the admissibility of evidence related to police conduct and disciplinary history. The decision underscores the importance of adhering to legal standards when pursuing claims against law enforcement officers.
What's Next
Chapdelaine's case is now concluded at the appellate level, and it is unclear if she will seek further legal recourse. There are no indications of related cases pending that could influence this ruling. The court's decision stands as a precedent for similar future cases involving claims against police officers.