Alexandre Ansari v. Moises Jimenez -Eastern District of Michigan at Detroit
Split Score
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Case Summary
Disposition
Affirmed
The Sixth Circuit affirmed a $10 million jury verdict for Alexandre Ansari, who spent years in prison before his convictions were vacated and who then sued Detective Moises Jimenez under 42 U.S.C. § 1983 for withholding exculpatory evidence. The court rejected Jimenez’s arguments that Heck v. Humphrey barred the suit, that he was entitled to qualified immunity, and that multiple trial errors required a new trial.
Circuit Split Identified
Legal Issue
Whether police officers have an independent, clearly-established duty under Brady v. Maryland to disclose exculpatory or impeachment evidence to prosecutors (and thus may be sued under §1983 for withholding it).
Circuit Positions
Police officers possess an independent, clearly established Brady duty to disclose exculpatory or impeachment evidence; violation can give rise to §1983 liability.
It was not clearly established that police officers had an independent Brady duty at the relevant time, so qualified immunity applies.
Conflict Summary
The Sixth Circuit has long held that police officers share the prosecution’s Brady obligations and that this duty was "clearly established" as early as 1990, making officers potentially liable under §1983 for nondisclosure. By contrast, Fourth Circuit precedent (Jean v. Collins, 221 F.3d 656 (4th Cir. 2000) (en banc), aff’d by an equally divided court) has been cited to argue that no such clearly established duty existed, thereby shielding officers with qualified immunity.