Carillo, Jr. v. Los Angeles, No. 12-57229 (9th Cir. 2015)
Annotate this CaseAfter Plaintiffs Frank O’Connell and Francisco Carrillo were wrongfully imprisoned for decades, they filed suit under 42 U.S.C. 1983 against the police investigators involved in their respective cases, arguing in part that the officers failed to disclose evidence that would have cast serious doubt on the testimony of key prosecution witnesses. The district court denied judgment on the pleadings in O’Connell’s case and summary judgment in Carrillo’s case. The court concluded that the law at the time of the investigations clearly established that police officers had to disclose material, exculpatory evidence under Brady. The court also concluded that any reasonable officer would have understood that Brady required the disclosure of the specific evidence allegedly withheld. Accordingly, the court affirmed the denials of qualified immunity and remanded these cases to the district court for further proceedings.
Court Description: Civil Rights. The panel affirmed the district court’s denial of qualified immunity to police officers in two separate actions brought under 42 U.S.C. § 1983 by plaintiffs, each of whom had been wrongfully imprisoned for decades before eventually securing habeas relief. Plaintiffs alleged that police officers failed to disclose evidence that would have cast serious doubt on the testimony of key prosecution witnesses. The panel held that the law in 1984 clearly established that police officers had to disclose material, exculpatory evidence under Brady v. Maryland, 373 CARRILLO V. CTY. OF LOS ANGELES 3 U.S. 83 (1963), and that any reasonable officer would have understood that Brady required the disclosure of the specific evidence allegedly withheld in these cases.
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