Maurice Snow v. Erik Nelson
634 F. App'x 151
6th Cir.2015Background
- Snow's §1983 claim against Nelson and Rankin for unlawful arrest and malicious prosecution.
- Investigation identified 'Emmitt' as Snow; informant and officers believed Snow was the dope dealer based on early video.
- Video from July 15, 2013 showed a green-shirted man; informant later identified Snow as Emmitt but not in video.
- Nelson and Rankin relied on informant and independent corroboration (address, name, lifestyle) to indict Snow.
- Snow was indicted after grand jury testimony; he was released and charges were dismissed; district court granted summary judgment for defendants.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady claim viability regarding misidentification evidence | Snow asserts Brady violation from misidentification disclosures | Disclosures timely; no prejudice; trial not pursued | No Brady violation; qualified immunity applies |
| Whether probable cause supported the Fourth Amendment malicious prosecution claim | Defendants knowingly/recklessly presented false testimony | No proof of false testimony; probable cause remains | Probable cause supported; indictment valid despite alleged misidentification |
Key Cases Cited
- United States v. Word, 806 F.2d 658 (6th Cir. 1986) (Brady disclosure timing governs prejudice)
- United States v. Crayton, 357 F.3d 560 (6th Cir. 2004) (Exculpatory disclosure timing matters for Brady)
- United States v. Presser, 844 F.2d 1275 (6th Cir. 1988) (Brady material timing re: effective use at trial)
- Garner v. United States, 507 F.3d 399 (6th Cir. 2007) (Reasonable probability standard for Brady)
- Gates v. Illinois, 462 U.S. 213 (1983) (Totality of circumstances; corroboration value)
- Sykes v. Anderson, 625 F.3d 294 (6th Cir. 2010) (Test for malicious prosecution elements; probable cause focus)
- Webb v. United States, 789 F.3d 647 (6th Cir. 2015) (Grand jury transcript absence affects falsity showing)
- Robertson v. Lucas, 753 F.3d 606 (6th Cir. 2014) (No clearly established duty to disclose Brady material before plea)
- Johnson v. Mitchell, 585 F.3d 923 (6th Cir. 2009) (Brady-related standards applied)
- McKinley v. City of Mansfield, 404 F.3d 418 (6th Cir. 2005) (Totality-of-the-circumstances probable cause)
- Williams v. Cambridge Bd. Educ., 370 F.3d 630 (6th Cir. 2004) (Probable cause analysis in arrest/prosecution)