Moises Jimenez v. Alexandre Ansari

No decision of this Court has ever clearly established that police officers bear independent obligations under Brady v. Maryland, 373 U.S. 83 (1963), or whether inadmissible evidence can be material for purposes of Brady. The circuits are split as to: (1) the level of culpability required to impose liability on a police officer under Brady, and (2) whether the withheld evidence must be admissible for a viable Brady claim. Moises Jimenez—a retired detective—investigated a 2012 shooting and was sued in 2020, with Ansari requesting $26,195,000 at trial. The district court denied qualified immunity. The Sixth Circuit affirmed, relying on Moldowan v. City of Warren, 578 F.3d 351 (6th Cir. 2009) and Est. of Andrews v. City of Cleveland, Ohio, 112 F.4th 436 (6th Cir. 2024) to hold police officers’ Bradyderived duties are clearly established. The Sixth Circuit cited no precedent from this Court holding Brady applied to police officers as of 2012-2013. The Sixth Circuit then refused to consider Jimenez’s argument that no clearly established law alerted him that uncorroborated rumors and anonymous tips should have been disclosed, finding Jimenez did not sufficiently raise this precise argument in his pre-verdict oral motion for judgment as a matter of law under Fed. R. Civ. P. 50(a). This petition presents an opportunity to resolve these important questions: I. Did the Sixth Circuit err in denying qualified immunity to Jimenez on Ansari’s Brady claim where no decision of this Court has ever clearly established that police officers bear independent obligations under Brady?