Postconviction Relief-Evidence

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7^th Circuit Court of Appeals

Case Name: Nakiya Moran v. Calumet City, Illinois

Case No.: 22-1043

Officials: Wood, Hamilton, and St. Eve, Circuit Judges.

Focus: Postconviction Relief-Evidence

Moran was convicted of attempted murder and aggravated battery with a firearm for a 2006 shooting in Calumet City, Illinois. After the trial, the prosecution learned that exculpatory evidence, including a ballistics report linking the gun used in the Calumet City shooting to a different shooting, had not been turned over to the defense as required by Brady v. Maryland, 373 U.S. 83 (1963). Moran sought postconviction relief based on the Brady violation, and a state court vacated his conviction. Moran was retried in a bench trial and acquitted in 2017.

Moran then filed this suit in federal court, seeking redress for the decade he spent behind bars. He brought federal and state claims against the city, two detectives who investigated the shooting, and a crime scene technician who mishandled the ballistics report. The district court granted the defendants’ motion for summary judgment. In its ruling, the district court noted a mistaken allegation in Moran’s complaint. This allegation was a judicial admission that negated an essential element of one of Moran’s theories of liability. Hoping for another chance to pursue this legal theory, Moran moved for leave to amend his complaint, but the court denied his motion. Moran appealed.

The district court properly entered summary judgment in the defendants’ favor and did not abuse its discretion in denying Moran leave to amend his complaint. Moran unduly delayed seeking to amend his complaint; he should have known that his complaint contained factual errors at the outset.

Affirmed.

Decided 11/23/22

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