The Sixth Circuit has upheld a $10 million jury verdict for a Michigan man who spent more than six years in prison before prosecutors concluded he was not guilty of murder, ruling that a Detroit detective could not use the man's vacated conviction to block his civil rights suit.
A three-judge panel on Thursday affirmed judgment for Alexandre Ansari, who sued Detroit police detective Moises Jimenez under Section 1983 after a Wayne County court vacated his convictions for first-degree murder and assault with intent to commit murder.
Jimenez argued that Ansari's claim was barred under the
U.S. Supreme Court's
Heck v. Humphrey, which prevents Section 1983 suits that would contradict an outstanding criminal conviction unless the conviction has been invalidated.
The Sixth Circuit rejected that argument, pointing to the Wayne County Circuit Court order stating that "Ansari's convictions and sentences in this matter are hereby vacated, and all related charges are hereby dismissed."
"Ansari's convictions and sentence have in fact been invalidated," U.S. Circuit Judge Joan L. Larsen wrote for the panel. "So the Heck bar does not apply."
Ansari was convicted in Michigan state court in connection with the 2012 shooting death of 15-year-old Ileana Cuevas and wounding Cuevas' older sister Rosalind Barley and Barley's boyfriend Miguel Figueroa. Ansari was sentenced to life in prison without parole in September 2013.
But the Wayne County Prosecutor's Office Conviction Integrity Unit later concluded Ansari was not guilty and that another man, Jose Sandoval, likely orchestrated the shootings, the opinion said.
The court highlighted a conviction integrity unit memo that said Sandoval, a drug dealer, had a motive because Barley and Figueroa had allegedly stolen heroin from him. The memo also criticized Jimenez, saying he "admitted to deliberately failing to investigate Jose Sandoval because Sandoval is tied to a powerful Mexican drug cartel."
"This distorted every aspect of his investigation and the truth-finding process," the memo said, according to the opinion.
After prosecutors and Ansari filed a stipulated order, a Wayne County judge vacated Ansari's convictions and sentence and dismissed all related charges. Ansari was released from prison after 6½ years in March 2019.
Ansari then sued Jimenez and the city of Detroit, claiming they violated his constitutional rights. The city was dismissed from the suit and the case against Jimenez went to trial on whether the detective withheld material exculpatory evidence under the Supreme Court's
Brady v. Maryland and
Giglio v. United States.
A first trial ended in a mistrial and a second jury found for Ansari in February 2024, awarding him $10 million in damages.
Jimenez also argued the state court's order may not have complied with Michigan post-conviction procedures, but the panel said federal courts do not get to disregard the state judgment on that basis.
The Sixth Circuit also rejected Jimenez's qualified immunity defense, stating the circuit had clearly established by 2012 that police officers have Brady disclosure duties.
Jimenez challenged the trial court's evidentiary rulings, verdict form, jury instructions and Ansari's closing argument, but the panel found no reversible error.
Although the panel questioned the trial court's decision to exclude evidence about Ansari's guilt or innocence from the civil trial, it said the parties had agreed not to litigate that issue and had not appealed the rulings implementing that agreement.
The panel also found the district court reasonably excluded a 911-page prosecutor's office file and limited the jury's review of an internal prosecutor memo, concluding that the excluded material risked unfair prejudice and confusion.
The court said Ansari's counsel made "some unusual turns" in closing argument, but the district court sustained objections and the comments did not warrant a new trial.
The parties did not immediately respond to requests for comment Friday.
U.S. Circuit Judges Alice M. Batchelder, Ronald Lee Gilman and Joan L. Larsen sat on the panel for the Sixth Circuit.
Ansari is represented by Beth A. Whitmann of Granzotto & Whitmann PC and Wolfgang Mueller of Mueller Law Firm.
Jimenez is represented by Mary Massaron of
Plunkett Cooney PC.
The case is Alexandre Ansari v. Moises Jimenez, case number
24-1743, in the
U.S. Court of Appeals for the Sixth Circuit.
--Editing by Kelly Duncan.