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Alvarez v. City of Brownsville

904 F.3d 382 (2018)

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Alvarez v. City of Brownsville

United States Court of Appeals for the Fifth Circuit

904 F.3d 382 (2018)

Facts

George Alvarez (plaintiff) was involved in a fight with a police officer for the city of Brownsville (Brownsville) (defendant) while Alvarez was being transferred from a holding area to a padded room because he had begun acting disorderly. Alvarez was charged in Texas state court with assault on a public servant. Alvarez pleaded guilty. Four years later, it was discovered that the prosecution failed to disclose a video of the incident that tended to show Alvarez’s innocence. Alvarez filed a writ of habeas corpus with the Texas Court of Criminal Appeals, which found that Alvarez was innocent of the assault charge. The criminal charges against Alvarez were dismissed. Alvarez filed a civil-rights claim against Brownsville in federal district court and was awarded a $2.3 million judgment. Brownsville appealed. A panel of the United States Court of Appeals for the Fifth Circuit held that Alvarez’s civil-rights claim should be dismissed and the monetary judgment reversed. Alvarez sought an en banc rehearing from the Fifth Circuit, arguing that the prosecution’s failure to disclose the video constituted a Brady violation because it was exculpatory evidence and, therefore, Alvarez was constitutionally entitled to its disclosure prior to his entry of a guilty plea.

Rule of Law

Issue

Holding and Reasoning (Stewart, C.J.)

Concurrence (Ho, J.)

Dissent (Costa, J.)

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