Plaintiff was awarded ten million dollars by a jury.
Det. Jimenez has now admitted to deliberately failing to investigate Jose Sandoval because Mr. Sandoval is tied to a powerful Mexican drug cartel. Det. Jimenez has family in Mexico, and Det. Jimenez feared his family would be killed … The district court didn’t err by denying qualified immunity to Det. Jimenez on Mr. Ansari’s Brady claim.
Ansari v. Jimenez
Sixth Circuit Appellate Court
May 14, 2026
Why is this case important?
Ansari v. Jimenez is important because it reinforces that law enforcement officers and prosecutors have a constitutional duty to disclose exculpatory and impeachment evidence under Brady v. Maryland, 373 U.S. 83 (1963) and Giglio v. United States, 405 U.S. 150 (1972). This case also underscores that all law enforcement officers, most especially detectives are trained on Brady and Giglio Doctrines. Not trained on a computer, but actually trained. Don’t fail your training and don’t let your training fail you. Do not turn a suspect into a plaintiff.
Background
Alexandre Ansari was convicted in Michigan state court of first-degree murder and two counts of assault with intent to commit murder. He was sentenced to life in prison without the possibility of parole. But a review conducted by the local prosecutor’s office later concluded that Mr. Ansari was not guilty of the crimes. In response, the state court vacated Mr. Ansari’s convictions and sentence pursuant to a stipulated order. Mr. Ansari then filed this federal action against Det. Moises Jimenez, the detective who investigated the crimes. Mr. Ansari alleged that Det. Jimenez failed to disclose material exculpatory evidence in violation of Mr. Ansari’s constitutional rights. A jury found for Mr. Ansari and awarded him $10 million in damages. Det. Jimenez now appeals. We AFFIRM.
Homicide of Ileana Cuevas
The events that led to Mr. Ansari’s conviction began on September 22, 2012, when Rosalind Barley and her younger sister, Ileana Cuevas, drove to Miguel Figueroa’s home in Detroit, Michigan. People v. Ansari, 2015 WL 630388 (Mich. Ct. App. Feb. 12, 2015). Ms. Barley testified at Mr. Ansari’s criminal trial that when they arrived, Mr. Figueroa, who was Ms. Barley’s boyfriend, got in the back seat of the car. Ms. Barley then “heard a series of loud noises that sounded like fireworks.” Id. Ms. Barley testified “that she did not immediately realize the noises were gunshots hitting her vehicle; however, after looking out the passenger window, she saw [Mr. Ansari] across the street holding a long gun.” Id. Mr. Figueroa also testified that he saw Mr. Ansari fire a weapon toward the vehicle. Id. Mr. Figueroa quickly got out of the car and Ms. Barley drove away. Id. Ms. Barley then realized that Ms. Cuevas had been shot. Id. Mr. Figueroa tried to flee but was shot twice as he was running away. Id. Mr. Figueroa “testified that after being shot, he turned around in order ‘to get a good look at [the shooter] again,’ and was then shot in the face.” Id. He nonetheless survived. Ms. Cuevas, however, died from the gunshot wound.
The homicide of Ms. Ileana Cuevas occurred near the intersection of Cicotte Street and Michigan Avenue in Detroit, Michigan.
Photographic and Live Lineups – Mr. Ansari is Identified by Witnesses
Ms. Barley and Mr. Figueroa were each shown photographic arrays not containing Mr. Ansari’s picture. Id. Neither could identify the shooter. Later, Mr. Figueroa was shown a photographic array that did include Mr. Ansari, and Mr. Figueroa identified Mr. Ansari as the shooter. Id. Ms. Barley was shown the same array, but she could not identify the shooter. At a subsequent live lineup, however, both Ms. Barley and Mr. Figueroa identified Mr. Ansari as the shooter. At trial, they did the same.
Contradictory Eyewitness
Mr. Ansari attempted to counter the in-court identification with the testimony of Leola Marlowe. Ms. Marlowe had heard the gunshots and had seen “a man with a gun run down the alley . . . , place the gun in the trunk of a car, and drive away.”. Ms. Marlowe testified that the man she saw was a “a big man – a heavy man,” who was close to 300 pounds and “really tall.” This was consistent with witness identifications of the shooter during the investigation, which described the shooter as possibly 6 feet tall and “fat (not sloppy) 300 lbs,” and as “a heavy set black male about 6 foot tall Mr. Ansari is around 5’11” tall but weighs around 175 pounds. Ms. Marlowe testified that she knew Mr. Ansari from the neighborhood and that he was not the person she saw because Mr. Ansari “is too small.”. The prosecution called Moises Jimenez, the City of Detroit police detective who investigated the murder, to rebut Ms. Marlowe’s testimony. He “testified that when he interviewed Ms. Marlowe immediately after the shooting she was nervous, shaky, and scared.”
Mr. Ansari is Convicted – Life Without Parole
Mr. Ansari was convicted of first-degree murder and two counts of assault with intent to commit murder. He was sentenced to life in prison without the possibility of parole. The Michigan Court of Appeals affirmed, id., and the Michigan Supreme Court denied leave to appeal, People v. Ansari, 869 N.W.2d 590 (Mich. 2015) (mem.). Mr. Ansari then filed a habeas petition in federal district court.
Mr. Ansari is Acquitted in a Related Murder
Four days after Ms. Cuevas’s death, Tommy Edwards, Mr. Figueroa’s brother, was shot and killed. Det. Jimenez, who investigated the Ms. Cuevas murder, also investigated the Edwards murder. Ultimately, Mr. Ansari was tried for the Edwards murder, but a jury acquitted him.
Conviction Integrity Unit Opposes Mr. Ansari’s Conviction
Mr. Ansari continued to profess his innocence of the Ms. Cuevas murder as well. And, in 2018, the Wayne County Prosecutor’s Office Conviction Integrity Unit (CIU) began an investigation. An attorney at the CIU drafted a memorandum that concluded that Jose Sandoval, Ms. Barley’s ex-boyfriend, likely had orchestrated the shootings. The memo explained:
Conviction Integrity Unit Memo – Homicides Began with Stolen Heroin
[The Ms. Cuevas and Edwards] cases must be viewed together inasmuch as they provide the background and support for the recommendation of the CIU. The murders were set in motion after Rosalind Barley and her new boyfriend, Miguel Mr. Figueroa[,] allegedly stole 3.5 grams of raw heroin from Ms. Barley’s ex-boyfriend, Jose Sandoval, in the Spring/Summer of 2012. Mr. Sandoval, a known drug dealer with significant ties to a Mexican Cartel, was being investigated by the DEA at the time of the murders. As a result, trackers were placed on two of his cars and his cell phones were confiscated when he was arrested for a violation of his supervised release on federal drug charges. A recent CIU review of the tracker and phone data, as well as new witness interviews, contribute significantly to our conclusion that Jose Sandoval arranged for these killings, and that persons other than Mr. Mr. Ansari carried them out.
The memo further explained that “victims Ms. Barley and Mr. Figueroa are now believed to have also been sabotaging the investigation: concealing their theft of Mr. Sandoval’s heroin, and deliberately throwing off the investigation of the real perpetrators by offering bogus descriptions, and ID’s, of the shooter.” Id. at 1378. The memo was particularly critical of Det. Jimenez, whom CIU investigators interviewed. The memo explained that Det. Jimenez “has now admitted to deliberately failing to investigate Jose Sandoval because Mr. Sandoval is tied to a powerful Mexican drug cartel. Det. Jimenez has family in Mexico, and Det. Jimenez feared his family would be killed.” Id. at 1377. According to the CIU, “[T]his distorted every aspect of his investigation and the truth-finding process.”
Wayne County Prosecutor Files to Dismiss Charges Against Mr. Ansari
Soon after, the Wayne County Prosecutor and Mr. Ansari filed a stipulated order in state court to dismiss the charges against Mr. Ansari. A Wayne County Circuit Judge then entered the following order:
This matter having been presented in open court through the stipulation of the parties, and the parties hav[ing] agreed that newly discovered evidence, as well as the Wayne County Prosecutor’s own investigation, warrants relief, and the Court being otherwise fully advised in the premises of said stipulation; IT IS HEREBY ORDERED that in the interests of justice, Alexandre Mr. Ansari’s convictions and sentences in this matter are hereby vacated, and all related charges are hereby dismissed. Mr. Mr. Ansari shall be released from the Michigan Department of Corrections forthwith.
Mr. Ansari is Released from Prison
Mr. Ansari was released from prison on March 15, 2019. A few days later, the federal district court dismissed Mr. Ansari’s previously filed habeas petition as moot, given that his “conviction and sentence ha[d] been vacated based on newly discovered evidence of actual innocence, and the charges dismissed.”
Civil Lawsuit Against the City of Detroit and Det. Jimenez
Once released from prison, Mr. Ansari brought this civil action under 42 U.S.C. § 1983, alleging that Det. Jimenez and the City of Detroit had violated his constitutional rights. The district court dismissed the City from the case with prejudice. And, after protracted litigation, Mr. Ansari’s case against Det. Jimenez boiled down to one issue—whether Det. Jimenez had violated Mr. Ansari’s Fourteenth Amendment rights by withholding material and exculpatory information under Brady v. Maryland, 373 U.S. 83 (1963), and Giglio v. United States, 405 U.S. 150 (1972).
Mr. Ansari is Awarded Ten Million Dollars in a Jury Verdict
Trial began in June 2023 but soon ended in a mistrial. A second trial began in February 2024. This time, the jury found for Mr. Ansari and awarded him $10 million in damages. During trial, Det. Jimenez moved for judgment as a matter of law. The district court denied the motion. After judgment was entered, Det. Jimenez moved for a new trial and filed a renewed motion for judgment as a matter of law. The district court denied the motions. Det. Jimenez now appeals.
Det. Jimenez Appeals
Det. Jimenez makes three claims on appeal: (1) Mr. Ansari’s § 1983 claim is barred by Heck v. Humphrey, 512 U.S. 477 (1994); (2) Det. Jimenez is entitled to qualified immunity; and (3) Det. Jimenez is entitled to a new trial. We address each in turn.
Established Case Law Barring the Lawsuit
Det. Jimenez first argues that Heck v. Humphrey, 512 U.S. 477 (1994), bars Mr. Ansari’s § 1983 claim. Det. Jimenez raised his Heck argument in a motion to dismiss, in a motion for judgment as a matter of law, and in a renewed motion for judgment as a matter of law. We review the district court’s decision on all such motions de novo. See In re Fifth Third Early Access Cash Adv. Lit., 925 F.3d 265, 275 (6th Cir. 2019); Pouillon v. City of Owosso, 206 F.3d 711, 719 (6th Cir. 2000).
“The Heck doctrine addresses a common situation.” Chaney-Snell, 98 F.4th at 707. Convicted defendants often sue under § 1983, claiming “that public officials violated the Constitution while investigating or prosecuting” them. Id. When a §1983 litigant seeks “a purely prospective remedy,” Heck poses no barrier to the lawsuit. Olivier v. City of Brandon, 146 S. Ct. 916, 920 (2026). But Heck prevents “the use of § 1983 to challenge the validity of a prior conviction or sentence so as to obtain release from custody or monetary damages.” Id. So when a litigant seeking such a remedy brings a lawsuit that “would necessarily imply the invalidity of” the underlying conviction, Heck bars the lawsuit unless the plaintiff “can demonstrate that the conviction or sentence has already been invalidated.” Heck, 512 U.S. at 487. That is, the plaintiff must show “that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal court’s issuance of a writ of habeas corpus.’”
A Conviction and Sentence that are Invalidated Bar the Heck Claim
The Heck bar does not apply here. Mr. Ansari’s lawsuit does seek damages. And we assume, as do the parties, that success on Mr. Ansari’s due process claim would imply the invalidity of his state court convictions and sentence. Richmond v. Mosley, 2024 WL 2862505, at *2 (6th Cir. June 6, 2024). But a cursory review of the procedural history shows that Mr. Ansari’s convictions and sentence have in fact been “invalidat[ed].” Heck, 512 U.S. at 487.
The Wayne County Circuit Court order is clear and unambiguous—it states that “Mr. Ansari’s convictions and sentences in this matter are hereby vacated, and all related charges are hereby dismissed.” The Circuit Court’s Register of Actions reflects this with the following notation—“Original Conviction Vacated.” And, consistent with the Circuit Court’s order that “Mr. Ansari shall be released from the Michigan Department of Corrections forthwith,” Mr. Ansari was released from prison on the day the state court order entered. So there can be little doubt that Mr. Ansari’s convictions and sentence have been invalidated. Mr. Ansari’s civil “action, even if successful, will not demonstrate the invalidity of any outstanding criminal judgment against” him. Heck, 512 U.S. at 487 So the Heck bar does not apply.
Should the Court Grant Det. Jimenez Qualified Immunity?
Det. Jimenez next argues that the district court erred by denying him qualified immunity on Mr. Ansari’s claim under Brady v. Maryland, 373 U.S. 83 (1963).3 A Brady claim has “three elements: ‘[1] the evidence at issue must be favorable to the accused, either because it is exculpatory, or because it is impeaching; [2] that evidence must have been suppressed by the State, either willfully or inadvertently; and [3] prejudice must have ensued.’” Jackson v. City of Cleveland, 925 F.3d 793, 814 (6th Cir. 2019) (quoting Strickler v. Greene, 527 U.S. 263, 281–82 (1999)). We have held that the “[P]olice share this obligation.” Est. of Andrews v. City of Cleveland, 112 F.4th 436, 443 (6th Cir. 2024). At trial, Mr. Ansari argued that Det. Jimenez had failed to disclose information regarding Mr. Sandoval’s potential role in the shooting, including, among other things, Mr. Sandoval’s status as a major drug dealer, the fact that Mr. Sandoval was nearby on the night of the shooting but had no communication with Mr. Ansari, and the fact that the only eye-witnesses, Mr. Figueroa and Ms. Barley, had recently stolen heroin from Mr. Sandoval (collectively, “the Mr. Sandoval information”).
Established Case Law – Qualified Immunity
We review the district court’s denial of qualified immunity de novo. Klein v. Long, 275 F.3d 544, 550 (6th Cir. 2001). A qualified immunity analysis asks “(1) whether, considering the allegations in a light most favorable to the party injured, a constitutional right has been violated, and (2) whether that right was clearly established” at the time of the relevant conduct. Harris v. Klare, 902 F.3d 630, 637 (6th Cir. 2018). The court may grant qualified immunity on either basis. Pearson v. Callahan, 555 U.S. 223, 241–42 (2009).
On appeal, Det. Jimenez focuses on the clearly established prong. He makes two arguments in this regard.
First, citing Fourth Circuit caselaw, Det. Jimenez briefly contends that in 2012, when the acts here occurred, it was not clearly established that police officers had independent duties under Brady. See Appellant Br. at 47 (citing Jean v. Collins, 221 F.3d 656 (4th Cir. 2000). Yet Det. Jimenez acknowledges that our circuit has deemed a police officer’s Brady duties “clearly established” since 1990. See Moldowan v. City of Warren, 578 F.3d 351, 382 (6th Cir. 2009).
What Level of Court can ‘Clearly Establish’?
To square this circle, Det. Jimenez argues that, in the years following Moldowan, the Supreme Court has suggested that circuit court cases cannot create a clearly established right; only Supreme Court caselaw will do. It is true that the Supreme Court has questioned whether circuit precedent can suffice. See, e.g., Rivas-Villegas v. Cortesluna, 595 U.S. 1, 6 (2021). But it has never squarely held that circuit precedent is insufficient. So we must follow our own precedent, which has repeatedly concluded that published caselaw from this court may create a clearly established right. See, e.g., Campbell v. Riahi, 109 F.4th 854, 860 (6th Cir. 2024). Moldowan held in 2009 that police officers’ Brady-derived duties were “clearly established” as far back as 1990. 578 F.3d at 382. We are bound by Moldowan; so this claim fails
Does a Detective have a Brady-Duty to Turn Over Uncorroborated Rumors and Anonymous Tips?
Next, Det. Jimenez contends that Mr. Ansari has produced no case that would have put Det. Jimenez on notice that Brady required him to turn over the particular “kind of information at issue” in this case, which he describes as “uncorroborated rumors and anonymous tips.” This court recently considered a similar argument, albeit at the summary judgment stage. In Clark v. Louisville-Jefferson County Metro Government, the defendant, a forensic scientist at a police crime lab, argued that he was entitled to qualified immunity because “no case ha[d] clearly established” a Brady duty to turn over the kind of evidence he had failed to disclose—his “‘unfinished notes’ that contain[ed] only initial ‘thoughts and impressions.’” 130 F.4th 571, 583 (6th Cir. 2025). This court rejected that argument. “Contrary to [the defendant’s] claim,” Clark held that our “cases do not require plaintiffs to identify a decision that addressed exactly the same type of Brady evidence.” Id. The parties do not discuss Clark. And we need not decide whether Clark’s reasoning applies here because Det. Jimenez did not raise this argument in his Rule 50(a) motion below. So it is not preserved for appeal.
“[A] party seeking a qualified-immunity defense must continue to urge it during and after trial in order to avoid forfeiting the argument on appeal.” Ayers v. City of Cleveland, 773 F.3d 161, 167 (6th Cir. 2014). The failure to do so forfeits the defense. See Sykes v. Anderson, 625 F.3d 294, 304 (6th Cir. 2010).
Det. Jimenez Failed to Raise the Clearly Established Argument in the District Court
During his oral new trial motion, Det. Jimenez primarily argued that there was no constitutional violation because he had turned over the purported Brady material, and, in any event, the information was neither material nor exculpatory. Then, with respect to the “clearly established” prong, Det. Jimenez made two arguments. He argued that because the circuits were split on the point, Moldowan’s holding on a police-officer’s Brady duties could not clearly establish the law. And he briefly mentioned the clearly established prong in response to the district court’s question regarding Brady’s applicability to charging decisions. But he never argued what he claims now: that no clearly established law would have alerted him that the particular kind of information he withheld—“the Sandoval evidence providing a motive for the shooting” and “uncorroborated rumors and anonymous tips”—counted as Brady information. His failure to properly present his claim in his Rule 50(a) motion means that he forfeited it. See Sykes, 625 F.3d at 304; see also Ayers, 773 F.3d at 167. After all, the point of Rule 50(a) is to give the opposing party and the district court “the opportunity to simplify the trial by resolving some issues, or even all issues, without submission to the jury.” Ford v. County of Grand Traverse, 535 F.3d 483, 492 (6th Cir. 2008) Det. Jimenez never gave the district court that chance.
Det. Jimenez contests this conclusion. He points out that, in Sykes, this court held that the defendants’ Rule 50(a) motion had not preserved their qualified immunity claim “because the Defendants ‘never mentioned ‘qualified immunity,’” “clearly established law,” or similar terms “that might have put the court and the Plaintiffs on notice as to the Defendants’ qualified immunity claim.” 625 F.3d at 304. That is an apt description of Sykes, but it does not save Det. Jimenez’s case. Sykes does not stand for the proposition that the mere “mention” of “qualified immunity” in a Rule 50(a) motion suffices to preserve any and all qualified immunity claims for a post-trial motion or for appeal. The import of Sykes is that the Rule 50(a) motion must have done enough to “put the court and the Plaintiffs on notice as to the Defendants’ qualified immunity claim.” Id. Det. Jimenez’s incantation of “qualified immunity” with respect to two starkly different arguments was not sufficient to preserve the claim he now makes on appeal.
The district court didn’t err by denying qualified immunity to Det. Jimenez on Mr. Ansari’s Brady claim.
There were two additional appeals. One was for a new trial and the other on jury instructions, both those appeals were denied. Neither of those appeals are evaluated in this article.
Information for this article was obtained from Ansari v. Jimenez, No. 24-1743 (6th Cir., 2026) and several news stories.
https://www.law360.com/articles/2478032/6th-circ-upholds-10m-verdict-against-detective-in-brady-suit
Ansari v. Jimenez, No. 24-1743 (6th Cir., 2026) was issued by the Sixth Circuit Appellate Court on May 14, 2026 and is binding in Kentucky, Michigan, Ohio and Tennessee.
Lessons Learned
- What is a Brady Violation? On Monday May 13, 1963 the U.S. Supreme Court issued Brady v. Maryland, 373 U.S. 83 (1963). The court held that the prosecution, which would include law enforcement, has a duty to disclose exculpatory evidence to the defense. Specifically, the court held “We now hold that the suppression by the prosecution of evidence to an accused upon request violates due process where the evidence is material either to guilt or punishment, irrespective of the good faith or bad faith of the prosecution.” Brady v. Maryland, 373 U.S. 83 (1963). Exculpatory Evidence – Clearing or tending clear from alleged fault or guilt. Blacks Law Dictionary, 566 (6th 1990). Consequently, law enforcement has a legal duty to disclose any evidence or information that is obtained that tends to clear the suspect/defendant. Not every case will include evidence that indicates the suspect committed the crime, but the suspect may still have committed the crime. Nevertheless, law enforcement must disclose any information beneficial to the suspect/defendant to the prosecutor, who in turn, must share that with the suspect/defendant’s defense team. In this case there was exculpatory evidence that was withheld from the defense.
- What is a Giglio Violation? On February 14, 1972, the U.S. Supreme Court issued Giglio v. U.S., 405 U.S. 150 (1972) and held “When the reliability of a given witness may well be determinative of guilt or innocence, nondisclosure of evidence affecting credibility falls within this general rule.” The general rule is a reference to Brady violation – Brady v. Maryland, 373 U.S. 83 (1963). Giglio mandates that the prosecution inform the defense that a witness has credibility challenges. In this case Ms. Barley and Mr. Figeuroa had integrity challenges that should have been shared with the prosecution by Det. Jimenez and were withheld.
- What the Heck the Heck Doctrine? On June 24, 1994 the U.S. Supreme Court issued Heck v. Humphrey, 512 U.S. 477 (1994) and held “We hold that, in order to recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid, a §1983 plaintiff must prove that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorize to make such a determination, or called into questions by a federal court’s issuance of a writ of habeas corpus.”. The Heck Doctrine holds that if a defendant is convicted of a crime that conviction bars the defendant from successfully suing for a §1983 claim on actions that led to the defendant’s conviction. In this case Det. Jimenez argued that Mr. Ansari was convicted of the homicide of Ms. Ileana Cuevas. However, that conviction was overturned that permitted the §1983 suit to move forward.
- What went Wrong? During the homicide investigation, it was revealed that a different suspect, Mr. Jose Sandoval, was part of a Mexican Drug Cartel and killed Ms. Ileana Cuevas. However, Det. Jimenez pursued the investigation of Mr. Ansari because the detective feared for his family’s safety in Mexico from Mr. Sandoval’s drug cartel. As the court explained “The memo explained that Det. Jimenez “has now admitted to deliberately failing to investigate Jose Sandoval because Mr. Sandoval is tied to a powerful Mexican drug cartel. Det. Jimenez has family in Mexico, and Det. Jimenez feared his family would be killed.” Id. at 1377. According to the CIU, “[T]his distorted every aspect of his investigation and the truth-finding process.”. Det. Jimenez had information that Mr. Sandoval was the killer but withheld that evidence and that is the Brady violation, that was the pathway to Mr. Ansari’s successful civil litigation and ten-million-dollar verdict.
- Don’t Fail Your Training and Don’t Let Your Training Fail You – All law enforcement officers, most especially detectives and officers investigating felonies should be trained on Brady v. Maryland, 373 U.S. 83 (1963). The training should consist of the duty to inform prosecutors, in writing, of potential exculpatory information. Lack of Brady training can lead to additional successful lawsuits and overturned convictions for defendants who become successful plaintiffs.
Does your agency train on Brady Violations?
Don’t fail your training.
Don’t let your training fail you!
Be safe, smart and objectively reasonable!