Francisco Carrillo, Jr. v. County of Los Angeles

Frank O’Connell and Francisco Carrillo were wrongfully imprisoned for decades before eventually securing habeas relief. After release, they separately brought suit under 42 U.S.C. § 1983 in federal district court against the police investigators involved in their respective cases, arguing in part the officers failed to disclose evidence that would have cast serious doubt on the testimony of key prosecution witnesses. The defendant officers asserted qualified immunity, arguing the law at the time of the investigations did not clearly establish the duty of police officers to disclose material, exculpatory evidence under Brady v. Maryland, 373 U.S. 83 , 83 S.Ct. 1194 , 10 L.Ed.2d 215 (1963). The district court denied judgment on the pleadings in O’Connell’s case and summary judgment in Carrillo’s case, concluding the officers’ duty to disclose Brady evidence was clearly established at the time of the investigations. The officers challenge these determinations on appeal.

We conclude, first, that the law at the time of the investigations clearly established that police officers had to disclose material, exculpatory evidence under Brady , and second, that any reasonable…