Fourteenth Amendment Due Process Claim Fails Without Evidence Officer Knowingly Made False Report By Sarah B. Jansen & Stephanie W. Weiner on October 1, 2025 Email this postTweet this postLike this postShare this post on LinkedIn Summarizes Seventh Circuit ruling in Zambrano v. City of Joliet, which clarifies that a police officer’s false report only triggers Fourteenth Amendment liability if there’s sufficient evidence the officer knew the statement was false.