Douglas Jordan v. Blount Cty., 885 F.3d 413

In 1998 Jennifer Byerley was found murdered; Douglas Jordan was convicted of second-degree murder after prosecutors failed to disclose a nearby knife that could have implicated another person.
On direct review the conviction was affirmed, but Jordan later sought post-conviction relief based on Brady v. Maryland (suppression of exculpatory evidence).
In 2011 the Tennessee Court of Criminal Appeals vacated Jordan’s conviction and remanded for further proceedings under state post-conviction law.
Jordan was retried on remand and acquitted in March 2015.
Less than a year after acquittal Jordan sued under 42 U.S.C. § 1983 for the Brady violation; Tennessee’s one‑year statute of limitations applies.
The district court dismissed the suit as untimely, holding accrual occurred at the 2011 vacatur; the Sixth Circuit reversed, holding accrual occurred at the 2015 acquittal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
When does a § 1983 Brady claim accrue for statute‑of‑limitations purposes?	Accrues when the criminal proceedings finally terminate in the plaintiff’s favor — here, at acquittal in 2015.	Accrues when the conviction is vacated by the appellate/post‑conviction court (2011).	Accrual occurs when the criminal proceeding actually terminates in the plaintiff’s favor (2015 acquittal).

Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose exculpatory evidence to defense)
Heck v. Humphrey, 512 U.S. 477 (1994) (look to common‑law torts to determine § 1983 elements; malicious prosecution analogy)
Wallace v. Kato, 549 U.S. 384 (2007) (claim accrues when plaintiff can file suit and obtain relief)
King v. Harwood, 852 F.3d 568 (6th Cir. 2017) (vacatur on appeal does not necessarily terminate criminal proceeding; accrual when proceeding finally ends)
D'Ambrosio v. Marino, 747 F.3d 378 (6th Cir. 2014) (vacatur by writ of habeas that barred retrial terminated proceedings and triggered accrual)