Aguilera v. Wright County
2014 U.S. Dist. LEXIS 740
N.D. Iowa2014Background
- In 1996 Aguilera was convicted of second-degree murder; in 2011 the Iowa Supreme Court granted post-conviction relief finding a Brady violation because the prosecution failed to disclose a DCI file containing favorable witness statements, and ordered a new trial.
- A DCI investigative file contained inconsistent statements from multiple witnesses; that file was not disclosed to defense counsel until 2006.
- In 2012 the State retried/reprosecuted; Aguilera pleaded guilty to involuntary manslaughter and was sentenced to time served. He remains in custody and faces deportation.
- Aguilera sued under 42 U.S.C. § 1983 and state tort law against 1996 and 2012 prosecutors and DCI agents, alleging Brady/Giglio violations, fabrication/concealment of evidence, § 1983 conspiracy, intentional infliction of emotional distress, loss of consortium, fraud, and obstruction.
- The State Defendants moved to dismiss under Rule 12(b)(6); Aguilera conceded some state tort claims must be dismissed for sovereign-immunity reasons. The court relied on Rule 12(b)(6) standards and public records (including the Iowa Supreme Court decision) in ruling.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Count “37” plausibly alleges Brady/Giglio liability by 1996 DCI agents for withholding the DCI file | Aguilera: the withholding of the DCI file caused his wrongful conviction; DCI agents could be responsible and discovery should test that | State: complaint fails to plausibly connect 1996 agents to the suppression or to bad faith; conclusory allegations; qualified immunity | Court: denied dismissal as to failure to disclose the DCI file (plausible bad-faith inference from allegations); dismissed the subclaim alleging undisclosed "government agreements with witnesses" as speculative |
| Whether Counts 1, 5, 9 (§ 1983 against individual 1996 State Defendants) survive Heck v. Humphrey | Aguilera: his original murder conviction was reversed; his later plea to a lesser offense should not automatically bar § 1983 claims for damages arising from the original prosecution | State: Heck bars § 1983 claims that would imply invalidity of conviction/sentence | Court: denied dismissal on Heck ground at pleading stage — uncertain whether plea on retrial bars § 1983 claims; better resolved on summary judgment where full record/case law can be addressed |
| Whether Count 27 (§ 1983 against IAAG Brown for 2012 conduct) is barred or immunized | Aguilera: Brown acted investigatively in 2012 (so only qualified immunity) and alleged bad faith | State: Brown’s actions were prosecutorial (absolute immunity) and Heck bars claims because 2012 involuntary-manslaughter conviction not invalidated | Court: granted dismissal of Count 27 — Heck bars claim (2012 conviction not favorably terminated), so no need to decide immunity question |
| Whether the asserted state-law torts and related conspiracy/fraud claims against State Defendants survive sovereign-immunity and ITCA exceptions | Aguilera: IIED and loss-of-consortium are independent torts not barred; federal court has supplemental jurisdiction; exhaustion not required or would be futile | State: ITCA preserves sovereign immunity for false arrest/imprisonment, malicious prosecution, deceit, etc.; many asserted torts are functionally equivalent to excluded claims and no waiver exists; exhaustion also lacking | Court: dismissed state tort claims that are functional equivalents of excluded ITCA categories (malicious prosecution, false arrest/imprisonment, deceit); no subject-matter jurisdiction for those claims; conspiracy/fraud claims dismissed where they rest on the same excluded conduct |
Key Cases Cited
- Aguilera v. State, 807 N.W.2d 249 (Iowa 2011) (Iowa Supreme Court found Brady violation and ordered new trial)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution’s suppression of favorable evidence violates due process)
- Heck v. Humphrey, 512 U.S. 477 (1994) (§ 1983 damages claims barred unless conviction/sentence has been favorably terminated)
- White v. McKinley, 519 F.3d 806 (8th Cir. 2008) (Brady extends to investigators but proof of bad faith is required to hold investigators liable)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (further articulating plausibility standard under Rule 12(b)(6))
- Minor v. State, 819 N.W.2d 383 (Iowa 2012) (interpreting ITCA waiver and exceptions; functional-equivalency test for excluded torts)