Evidence-Scope of Brady Obligations

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7^th Circuit Court of Appeals

Case Name: Bernard Mims v. City of Chicago

Case No.: 24-1564

Officials: Scudder, Pryor, and Kolar, Circuit Judges.

Focus: Evidence-Scope of Brady Obligations

Mims spent ten years in prison following his conviction for murder, a conviction later vacated after the State’s Attorney’s Office lost confidence in the case for reasons unrelated to the present claim. Mims subsequently filed a civil rights action under 42 U.S.C. § 1983 against the City of Chicago and several police detectives. Among his allegations, Mims claimed that two detectives violated his due process rights by failing to disclose an audio recording of a conversation between two individuals, one of whom had previously implicated himself in the murder. Mims asserted that the recording was exculpatory because it pointed to another suspect.

The Northern District of Illinois granted summary judgment for the defendants on all counts. The court found no evidence that the detectives had concealed or withheld the recording from prosecutors. It further concluded that the recording was not material under Brady v. Maryland and, alternatively, that the detectives were entitled to qualified immunity.

The Seventh Circuit reviewed the decision de novo. The court found that Mims had failed to produce evidence showing that the detectives intentionally or recklessly withheld the recording from the prosecution. The panel noted that the prosecutor was aware of and had access to the recordings through the court file, and that the obligation to disclose exculpatory evidence under Brady rests primarily with the prosecution.

Affirmed.

Decided 10/21/25

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