Andrews v. City of Cleveland, 1:22-cv-00250

Isaiah Andrews was wrongfully convicted in 1975 for the murder of his wife and served 45 years in prison prior to his 2021 acquittal at retrial.
Andrews’s estate sued the City of Cleveland under 42 U.S.C. § 1983, alleging police withheld exculpatory evidence (a police report implicating an alternate suspect, Willie Watts), violating Brady v. Maryland.
The district court originally granted summary judgment in favor of Cleveland, finding no evidence the officers failed to give prosecutors exculpatory reports; thus, did not reach the Monell municipal liability theory.
On appeal, the Sixth Circuit reversed in part, finding a genuine factual dispute about whether the police withheld police report page 3 and remanded to determine City liability under Monell on official policy, custom, or training theories.
Andrews advances Monell claims based on (1) official policy (GPO 19-73), (2) inadequate police training, and (3) deliberate indifference/custom of non-disclosure; he insufficiently supported a ratification theory.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Monell Liability – Official Policy	GPO 19-73 was a written policy instructing non-disclosure of exculpatory	Policy did not mandate withholding, and other policies required disclosure	Sufficient factual issue to let jury decide official policy claim
Monell Liability – Ratification	Chief of Police had final policymaker authority and ratified misconduct	Chief’s authority not shown; no evidence of ratification or involvement	Not enough evidence; summary judgment for Cleveland
Monell Liability – Inadequate Training	Officers had no specific Brady training beyond variable on-the-job practice	Officers received 1974 rules training; no evidence of specific failure	Sufficient factual issue to proceed on training claim
Monell Liability – Deliberate Indifference/Custom	City had a longstanding indifferent custom and cover-up practice	Only isolated incidents, not a pattern; denies such a custom	Sufficient issue for trial, based on Jackson precedent

Monell v. Dep’t of Soc. Servs., 436 U.S. 658 (U.S. 1978) (establishes municipal liability for unconstitutional policies or customs)
Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (requires disclosure of exculpatory evidence to defense)
Jackson v. City of Cleveland, 925 F.3d 793 (6th Cir. 2019) (analyzes Cleveland PD’s disclosure policy under Monell)
Pembaur v. City of Cincinnati, 475 U.S. 469 (U.S. 1986) (establishes criteria for official policy liability under Monell)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment standard of genuine factual dispute)