The Lee Evans Malicious Prosecution Case:
What It Means for New Jersey Defendants
The disappearance of five Newark teenagers in 1978 shocked New Jersey. Decades later, the case resurfaced when prosecutors charged Lee Evans with their murders. His eventual acquittal did not end the legal fallout. In Evans v. City of Newark, the United States Court of Appeals for the Third Circuit ruled in 2025 that police officers accused of coercing a false confession and manufacturing evidence were not entitled to qualified immunity on Evans’s malicious prosecution claims.
This ruling carries profound consequences for anyone wrongfully accused of a crime in New Jersey. It underscores how fabricated evidence and coerced confessions can taint prosecutions—and why defendants need experienced criminal defense counsel to protect their constitutional rights.
What Happened in Newark in 1978
On August 20, 1978, five boys—Randy Johnson, Ernest Taylor, Melvin Pittman, Alvin Turner, and Michael McDowell—disappeared in Newark. Their remains were never recovered.
Initial police investigations produced conflicting information. Evans admitted the teens had worked with him that day, while his cousin, Philander Hampton, gave inconsistent statements. For decades, the case remained unsolved.
In the late 1990s, Newark’s Cold Case Unit reopened the investigation, but it still went nowhere. Everything changed in 2007 when the Essex County Prosecutor’s Office launched a new inquiry led by Detective Lou Carrega, later joined by Detective William Tietjen of the New Jersey State Police.
The Allegedly Coerced Confession
In 2008, investigators brought Hampton in for questioning. According to Evans’s lawsuit, Hampton initially denied knowing anything about the boys’ disappearance. After being told he failed a polygraph, detectives pressured him into blaming Evans. Hampton later testified that investigators threatened to charge him unless he implicated his cousin.
Detectives allegedly coached Hampton through the story, including details about a Camden Street house where the murders supposedly occurred. Hampton then gave a videotaped statement saying Evans trapped the boys in a closet, set the house on fire, and killed them.
Criminal Charges and Trial
With Hampton’s statement in hand, prosecutors charged both Evans and Hampton. Hampton accepted a plea deal: plead guilty to five counts of felony murder and testify against Evans in exchange for a reduced sentence.
At Evans’s 2011 trial, Hampton was the State’s star witness. Despite his testimony, the jury acquitted Evans on all counts.
Evans had lost years fighting charges that rested on what he claimed was a fabricated confession. In 2013, he filed a civil rights lawsuit under 42 U.S.C. § 1983, alleging malicious prosecution and fabrication of evidence.
Hampton’s Recantation
Years later, Hampton recanted. In 2017 and 2020, he signed sworn statements declaring that his 2008 confession had been coerced and fabricated by detectives Carrega and Tietjen. This recantation became central to Evans’s civil case.
Malicious Prosecution in New Jersey Law
To succeed on a malicious prosecution claim in New Jersey under § 1983, a plaintiff must generally prove that the defendant initiated a criminal proceeding, the proceeding ended in the plaintiff’s favor, it was initiated without probable cause, the defendant acted with malice, and the plaintiff suffered a deprivation of liberty consistent with a Fourth Amendment seizure. See Johnson v. Knorr, 477 F.3d 75 (3d Cir. 2007).
The Third Circuit in Evans’s case reaffirmed that probable cause cannot be based on fabricated or coerced evidence. As the court stated, police officers are never permitted to “cook up” evidence against a suspect.
The Qualified Immunity Defense
Qualified immunity shields government officials from liability unless they violated a clearly established constitutional right. Officers Carrega and Tietjen argued they reasonably relied on Hampton’s statement.
The court rejected this. It ruled that no reasonable officer could believe it lawful to prosecute someone based on evidence they themselves had manufactured. This placed Evans’s claims outside the protection of qualified immunity.
For defendants, this ruling is critical: it emphasizes that constitutional rights extend beyond the arrest. They also apply during prosecution and trial, protecting against fabricated evidence and coerced testimony.
Why This Case Matters for New Jersey Defendants
New Jersey courts recognize that coerced confessions violate both the Fifth Amendment and Miranda v. Arizona, 384 U.S. 436 (1966). If police pressure you into saying something against your will, that statement may not be admissible. This principle is reinforced in guidance from the New Jersey Courts’ Criminal Practice Division, which provides resources on protecting defendants’ rights.
The Evans decision also reminds us that probable cause must be based on legitimate evidence. When officers omit facts about coercion, the warrant process is tainted. For prosecutors, as noted in the Department of Justice Civil Rights Division, reliance on fabricated statements is not tolerated under federal law.
Even though Evans was acquitted, he still had to endure arrest, indictment, and trial. Malicious prosecution recognizes this ongoing harm. Defendants can seek damages for the stress, costs, and stigma of wrongful charges, an avenue supported under § 1983 civil rights claims and monitored by the New Jersey Attorney General’s Division on Civil Rights.
What To Do If You Face Wrongful Charges in New Jersey
If you believe you are the victim of malicious prosecution or a coerced confession in Camden, Trenton, or anywhere in New Jersey, you should never speak to investigators without counsel. Document all interactions with law enforcement, including threats or pressure tactics. Your attorney can file motions to suppress coerced confessions and may pursue civil remedies under § 1983.
For guidance, the Third Circuit Court of Appeals opinion archive shows how appellate rulings like Evans v. City of Newark shape future protections for defendants.
At Ratliff Jackson LLP, we defend clients against criminal charges and pursue justice when constitutional rights are violated.