Prosecutor Must Not Withhold Potentially Exonerating Evidence (Nakiya Moran v. Calumet City, Illinois)
Nakiya Moran was convicted for murder and aggravated battery with a firearm, arising out of a 2006 shooting in Calumet City, Illinois. After being convicted, the defendant learned that Calumet City had failed to turn over a ballistics report, which tied the firearm used to a different shooting. Moran alleged that this evidence had to have been turned over pursuant to Brady v. Maryland, 373 U.S. 83 (1963) (establishing the rule that the prosecution must turn over all evidence that might exonerate the defendant).
Moran sought postconviction relief under the Brady standard, a state court vacated the conviction and allowed a new bench trial in 2017. The new evidence was admitted at the retrial. Moran was acquitted.
Moran subsequently filed a lawsuit in federal court, seeking damages for the more than ten years he spent in federal prison. His complaint was brought against the city, detectives, and a crime scene technician. The Northern District of Illinois entered summary judgment in favor of the new defendants (the city and its employees), and the District Court denied Moran’s leave to file an amended complaint.
The issue in front of the Seventh Circuit Court of Appeals is whether the District Court abused its discretion in denying Moran’s leave to file an amended complaint.
In his complaint, Moran’s counts arise from: Section 1983, where he alleges the suppression violated his due process rights under Brady; fabrication of evidence, where he must prove a police office manufactured evidence to be used against him falsely (Whitlock v. Brueggemann, 682 F.3d 567, 580 (7th Cir. 2012); and state law claims, including malicious prosecution, civil conspiracy, and respondent superior and indemnity.
The question then turns over the standard upon which a trial judge can determine whether to permit leave to file an amended complaint. To file an amended complaint, the party must obtain written consent of the opposing party, or by obtaining leave from the court. F.R.C.P. 15(a)(2). Districts courts are generally expected to permit leave, unless there is a compelling reason not to, such as futility.
While the standard of review undertaken by the Seventh Circuit is based upon abuse of discretion (where the District Court found the amendment to be futile), the questions of law, which were used to determine the amendment to be futile, is reviewed de novo.
While the Seventh Circuit extensively discusses the facts of the case, the analysis based on the actual merits of the argument is rather brief. In short, the court appears to believe the case to largely be without merit, and therefore, it able to write deferentially to the District Court. The Seventh Circuit also notes that to sustain futility, allegations must be in some way based on fact, rather than be statements that are simply speculative in nature.
WHY THIS CASE IS NOTABLE
This case, including its procedural and past history is important as it stands to show two important concepts. First, it demonstrates the absolute requirement for the prosecutor to turn over all evidence which might be used to exonerate the defendant, in turn, this also shows how important it is that all of said evidence actually be turned over.
Secondly, the Seventh Circuit opinion provides instructive guidance on when a judge may properly deny motion for leave to file an amended complaint. While these are typically supposed to be granted, it is well within the discretion for the trial court to deny it when the allegations are not strong and those that are present, are primarily speculative.