Tyron Brown v. Lee Lucas
2014 U.S. App. LEXIS 9771
| 6th Cir. | 2014Background
- Mansfield Investigation (Operation Turnaround) involved Richland County Sheriff's Office using confidential informant Bray for controlled buys.
- DEA joined in 2005; Bray registered as an informant by Cross and Lucas; Bray conducted buys for RCSO.
- Seven individual appellees oversaw Bray: Metcalf, Mayer, Faith, Lucas, Ansari, Verhiley, and Cross.
- Appellants Robertson, Lovett, Spires, Matthews, Brooks, and Brown were targets and later indicted/arrested.
- Evidence showed Bray fabricating identifications, stealing money/drugs, and officers allegedly aiding or tolerating Bray’s misconduct.
- Bray ultimately pled guilty to perjury and civil rights deprivation; several officers faced related charges; indictments and pleas were dismissed or withdrawn, giving rise to this § 1983/Bivens action.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officers’ qualified immunity shields them from §1983/Bivens claims | Appellants allege personal constitutional violations by specific officers | Officers acted under color of law and no rights were violated | Yes; individual appellees entitled to qualified immunity |
| Whether Lucas’s grand jury testimony violated rights supporting false arrest/malicious prosecution | Lucas's testimony was knowingly false or reckless, tainting probable cause | No demonstrable false testimony; probable cause presumed from indictment | Lucas entitled to qualified immunity; no proven violation by appellants |
| Whether remaining officers violated rights by relying on tainted warrant based on grand jury | Warrant relied on false grand jury testimony; arrests unjustified | Probable cause established by indictment; no knowing reliance on false testimony shown | Qualified immunity for remaining officers; no individualized violation proven |
| Whether Brady claims against law enforcement were properly analyzed under Ruiz and qualified immunity | Withheld exculpatory impeachment material violated Brady; plea changes | Ruiz limited to impeachment material at trial; no clearly established pre-plea duty | No clearly established pre-plea Brady requirement; qualified immunity applies; remand denied; Monell Brady claim lacking specificity |
| Whether Monell claims against Richland County and City of Cleveland survive | Policies/customs caused constitutional violations | No underlying constitutional violation; no policy showing withholding Brady material | Affirmed dismissal of Monell Brady claims; generally affirmed dismissal of Monell claims |
Key Cases Cited
- Mott v. Mayer, 524 Fed.Appx. 179 (6th Cir.2013) (indictment validity and probable cause in false testimony context)
- Barnes v. Wright, 449 F.3d 709 (6th Cir.2006) (probable cause and grand jury reliance standards)
- Sykes v. Anderson, 625 F.3d 294 (6th Cir.2010) (malicious prosecution theory under Fourth Amendment)
- Gregory v. City of Louisville, 444 F.3d 725 (6th Cir.2006) (malicious prosecution and fabrication of evidence principles)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (personal liability requires individual action violating rights)
- Saucier v. Katz, 533 U.S. 194 (2001) (two-step qualified immunity analysis (Pearson modification))
- Pearson v. Callahan, 555 U.S. 223 (2009) (modifies sequence of qualified immunity questions)
- Voyticky v. Village of Timberlake, 412 F.3d 669 (6th Cir.2005) (probable cause and false arrest limitations)
- Ruiz v. United States, 536 U.S. 622 (2002) (Brady material and plea bargaining context)
- United States v. Wells, 260 Fed.Appx. 902 (6th Cir.2008) (Ruiz applicability to impeachment material)
- Campbell v. Marshall, 769 F.2d 314 (6th Cir.1985) (plea bargaining context and evidentiary basis)
- Word v. United States, 806 F.2d 658 (6th Cir.1986) (timeliness of Brady disclosures and prejudice)
- United States v. Conroy, 567 F.3d 174 (5th Cir.2009) (implication for Brady material handling)