Beaman v. Freesmeyer

Dist. Ct. did not err in granting defendants-police officers’ motion for summary judgment in section 1983 action alleging that defendants deliberately withheld from plaintiff favorable polygraph test results of alternative suspects during pendency of plaintiff’s criminal case on murder charges in violation of Brady. Said evidence did not qualify as Brady material since polygraph test results could not have been introduced at plaintiff's criminal trial, and defendants were otherwise entitled to qualified immunity since there was no case law at time of withholding that required that they turn over inadmissible polygraph test results to plaintiff. Defendants were also entitled to summary judgment on conspiracy count since: (1) defendants actually turned over test results to prosecutor who was entitled to absolute immunity from instant lawsuit; and (2) plaintiff could not establish evidence of defendants’ agreement to withhold said test results based solely on prosecutor’s decision not to turn over said results to plaintiff.