Jaime Rios v. Reynaldo Guevara, Michael Mason, Joann Halvorsen as Special Representative for Ernest Halvorsen, Deceased, City of Chicago

Summary

This document is a plaintiff's memorandum supporting a motion for judgment as a matter of law under Federal Rule of Civil Procedure 50(a) in a civil rights action in the Northern District of Illinois. Jaime Rios argues that defendant Reynaldo Guevara suppressed evidence that he beat Cristino Garcia during an interrogation and that the evidence was favorable, unavailable through reasonable diligence, and material to Rios's underlying criminal conviction. The memorandum requests judgment on those issues or judgment on the relevant Brady claim, with a trial on damages only.

Questions Presented

1. Whether judgment as a matter of law should resolve in Rios's favor the issue of whether Guevara suppressed evidence that Garcia denied involvement in the murder.
2. Whether judgment as a matter of law should resolve in Rios's favor the issue of whether Guevara suppressed evidence that he beat Garcia in an effort to obtain a false implication of Rios.
3. Whether the alleged suppressed evidence could have been discovered through the exercise of reasonable diligence.
4. Whether the alleged suppressed evidence was material under Brady and its progeny.
5. Whether judgment as a matter of law should be entered on Count XII, with a trial limited to damages.

Disposition

other