Haley v. City of Boston, 2011 U.S. App. LEXIS 19223

James Haley was convicted of first-degree murder in 1972; after undisclosed witness statements surfaced in 2005, his conviction was vacated and he was released after 34 years in prison.
Haley sued the City of Boston and twoDetectives (Kelley and Harrington) under 42 U.S.C. §1983 and state law for alleged nondisclosure and related misconduct.
District court dismissed the federal claims against the detectives on qualified immunity grounds and dismissed state-law claims for failure to present under Mass. Gen. Laws ch. 258, § 4.
Haley alleged a Brady-based no-fault disclosure obligation and a deliberate-suppression due-process violation, plus Monell municipal-liability theories and various negligence claims.
On appeal, the First Circuit reinstated Haley’s deliberate-suppression claim and reversed the dismissal of the City’s Monell claims, while affirming most other rulings.
The court remanded for further proceedings consistent with its opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the detectives’ nondisclosure violated Brady’s no-fault obligation	Haley's pleadings allege a Brady violation	Brady duty at the time ran to prosecutors, not police	Qualified immunity fails for deliberate-suppression claim; no-fault Brady duty not clearly established for police in 1972.
Whether the detectives’ conduct violated due process by deliberate suppression	Deliberate concealment of statements deprived Haley of fair trial	No clearly established right against such conduct for officers in 1972	Yes; the conduct violated due process; not protected by qualified immunity on the deliberate-suppression theory.
Whether Haley stated a cognizable Monell claim against the City	BPD policy or training failures caused unconstitutional nondisclosure	Pleadings insufficient or premature for municipal liability	District court erred; plausibility shown; Monell claims survive for discovery.
Whether state-law negligence claims were time-barred due to presentment requirements	Presentment tolled by Heck-like favorable-termination period	Presentment and accrual timelines not tolled; dismissal with prejudice appropriate	Dismissal with prejudice upheld for failure to present within statutory timeline; Heck tolling not applicable.

Brady v. Maryland, 373 U.S. 83 (1963) (no-fault disclosure obligation for evidence favorable to defendant)
Kyles v. Whitley, 514 U.S. 419 (1995) (materiality and responsibility for disclosure extend to police-known evidence; prosecutor’s duty remains)
Limone v. Condon, 372 F.3d 39 (2004) (general rule applying prior constitutional rights to specific conduct; not require identical facts)
Mooney v. Holohan, 294 U.S. 103 (1935) (due-process violation for deliberate deception by state actors)
Napue v. Illinois, 360 U.S. 264 (1959) (no deviation from due process when state allows false evidence to go uncorrected)
Pyle v. Kansas, 317 U.S. 213 (1942) (recognizes suppression of favorable evidence as due-process issue)
Brown v. Mississippi, 297 U.S. 278 (1936) (due-process protection against coerced or fabricated evidence)
Pearson v. Callahan, 555 U.S. 223 (2009) (two-step qualified-immunity framework, may skip to final step if right not clearly established)
Saucier v. Katz, 533 U.S. 194 (2001) (initial sequencing of qualified-immunity inquiry (altered by Pearson))
Monell v. Dep't of Soc. Servs., 436 U.S. 658 (1978) (municipal liability for own unconstitutional acts via policy or custom)
Owen v. City of Independence, 445 U.S. 622 (1980) (government entity vicarious liability limitations under §1983)
Barber v. City of Salem, 953 F.2d 232 (1992) (plausibility standard for municipal claims)