Alan Beaman v. Dave Warner, 2015 WL 156744

Beaman was convicted of Jennifer Lockmiller’s murder in 1995; the Illinois Supreme Court later overturned his conviction for Brady violations involving undisclosed evidence about an alternative suspect.
The Illinois Supreme Court held Murray evidence (polygraph, arrest history, domestic abuse, steroids) was undisclosed and material, leading to Beaman’s conviction reversal.
After release, Beaman filed a §1983 suit alleging Brady violations by Normal Police Department officers, prosecutors, and municipalities.
The district court granted summary judgment to remaining defendants, ruling Gates polygraph was not Brady material and Murray polygraph disclosure did not defeat immunity.
Beaman appeals, arguing (i) conspiracy to withhold Brady material exists; (ii) Gates polygraph was Brady material; (iii) defendants lacked qualified immunity for Murray polygraph non-disclosure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Gates’s polygraph report was Brady material.	Beaman argues the report was favorable and suppressed, contributing to a conspiracy.	Defendants contend the Gates polygraph was not material and thus not Brady material.	Gates polygraph not Brady material; non-disclosure not actionable.
Whether Murray’s polygraph non-disclosure was clearly established error denying immunity.	Beaman asserts Brady violation and lack of immunity.	Defendants argue no clearly established right in 1995 to disclose inadmissible polygraph results.	Defendants entitled to qualified immunity.
Whether summary judgment was proper on Beaman’s Brady conspiracy claim.	Beaman contends circumstantial evidence shows an agreement to withhold Brady material.	Defendants argue no evidence of agreement; Souk’s immunity bars liability.	Summary judgment proper; no triable conspiracy.

Carvajal v. Dominguez, 542 F.3d 561 (7th Cir. 2008) (Brady material/presence of favorable evidence must be suppressed)
Kyles v. Whitney, 514 U.S. 419 (U.S. 1995) (materiality standard requires reasonable probability of different outcome)
Goudy v. Basinger, 604 F.3d 394 (7th Cir. 2010) (reasonable probability standard applied to suppressed evidence)
United States v. Agurs, 427 U.S. 97 (U.S. 1976) (contextual evaluation of materiality; cumulative effect when evaluating suppression)
Wood v. Bartholomew, 516 U.S. 1 (U.S. 1995) (polygraph inadmissibility; impact on Brady material viability)
Steidl v. Fermon, 494 F.3d 623 (7th Cir. 2007) (Brady/materiality; pre- Wood framework)
Whitlock v. Brueggeman, 682 F.3d 567 (7th Cir. 2012) (establishing clearly established rights; collaboration with prosecutors)
Harris v. Kuba, 486 F.3d 1010 (7th Cir. 2007) (conspiracy liability standards for §1983)
Pety v. City of Chicago, 754 F.3d 416 (7th Cir. 2014) (de novo review of Brady suppression claims)
Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (two-step qualified immunity analysis)
Hope v. Pelzer, 536 U.S. 730 (U.S. 2002) (clearly established standard for qualified immunity)
Estate of Escobedo v. Martin, 702 F.3d 388 (7th Cir. 2012) (right is clearly established if reasonable officer would know unlawful)