Godfrey v. Trujillo

Background

Ricky Godfrey alleged that detectives Dennis Trujillo and Denis Browne fabricated evidence during the investigation of a 1992 murder. Godfrey alleged that the detectives pressured witness Michael Cannon to identify him as the shooter, including by threatening Cannon with possible prosecution and later telling him it was in his best interest to identify Godfrey after Cannon said he could not identify anyone in a photo lineup. Godfrey also alleged that the detectives failed to disclose information that could have undermined Cannon’s credibility.

Godfrey was convicted of murder and attempted robbery in 1993 and spent 31 years incarcerated. In 2023, a state court vacated the original convictions. The prosecution amended the criminal complaint, Godfrey pleaded no contest to attempted robbery and voluntary manslaughter, and he received a 24-year sentence. Because he had already served 31 years, he was released.

Godfrey brought four claims under 42 U.S.C. § 1983, which allows a person to seek damages for constitutional violations by state actors: (1) fabrication of evidence, (2) withholding favorable evidence under Brady v. Maryland, (3) failure to intervene, and (4) a claim against the City of Richmond based on an alleged policy, custom, or practice of failing to discipline officers. The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint adequately states a claim, and moved to strike certain allegations under Rule 12(f).

Heck Bar

The defendants argued that the § 1983 claims were barred by Heck v. Humphrey, which generally prevents damages claims that would imply the invalidity of a conviction or sentence unless that conviction or sentence has been reversed, vacated, or otherwise invalidated. The court rejected that argument. It determined that the original 1993 convictions had been vacated and that Godfrey’s 2023 convictions arose from a later plea proceeding. Because Godfrey’s claims concerned constitutional violations connected to the original convictions, a judgment in his favor would not invalidate the 2023 convictions.

Fabrication-of-Evidence Claim

The court held that Godfrey plausibly alleged a fabrication-of-evidence claim. Such a claim requires allegations that an official deliberately fabricated evidence and that the fabrication caused a loss of liberty. The court found that the alleged threats, inaccurate statements about possible punishment, unrecorded questioning, transportation of Cannon to an isolated location, and pressure to identify Godfrey supported a reasonable inference that the detectives used coercive investigative techniques likely to produce false information.

The court declined to resolve at the motion-to-dismiss stage whether Cannon would have falsely identified Godfrey because of Holman’s threats even without the detectives’ conduct. The court had to accept the complaint’s allegations as true and draw reasonable inferences for Godfrey at this stage.

The court also rejected the defendants’ qualified-immunity defense as to this claim. Qualified immunity can protect government officials from damages unless their conduct violated a clearly established constitutional right. Relying on Ninth Circuit precedent, the court concluded that the right not to be subjected to criminal charges based on deliberately fabricated evidence was clearly established when the alleged conduct occurred. The court therefore denied the motion to dismiss the fabrication-of-evidence claim.

Brady Claim

Brady v. Maryland requires the government to disclose favorable evidence that is material to guilt or punishment. The court rejected the defendants’ arguments that the Brady claim was barred by Heck or duplicated the fabrication claim. It concluded that the detectives’ alleged statements and Cannon’s initial inability to identify the shooter could plausibly have undermined Cannon’s credibility and therefore could support a separate Brady claim.

The court also determined that qualified immunity did not bar the Brady claim. It reasoned that information about threats, possible prosecution, or potential leniency affecting a key witness’s credibility is favorable evidence that must be disclosed. The court denied the motion to dismiss this claim.

City of Richmond Claim

Godfrey’s claim against the City of Richmond was based on municipal liability under Monell v. Department of Social Services. A Monell claim requires allegations that a local government’s policy, custom, or practice was the moving force behind the constitutional injury. Godfrey alleged that the City was deliberately indifferent because it failed to investigate and discipline officers despite prior misconduct.

The court concluded that the complaint did not plausibly allege a policy or practice of witness coercion or failure to disclose favorable evidence. Most of the alleged prior misconduct involved excessive force. The complaint included only one prior allegation related to witness coercion or a Brady violation, involving Browne’s alleged direction to a witness to identify a particular suspect. The court found that this lone allegation did not establish the required pattern of similar violations or show that the City’s alleged indifference caused Godfrey’s injuries.

The court granted the motion to dismiss the Monell claim, with leave to amend, because it could not conclude that amendment would be futile.

Motion to Strike and Disposition

The defendants asked the court to strike allegations about the “Cowboys,” an alleged faction of Richmond police officers, as irrelevant to the City claim. The court denied the motion to strike. Although the allegations did not presently establish the Monell claim, the court concluded they could have a possible bearing on issues such as witness coercion and therefore were not clearly immaterial.

The court granted the motion to dismiss the Monell claim, with leave to amend; denied the motion to dismiss the fabrication-of-evidence and Brady claims; and denied the motion to strike. The court set September 15, 2025, as the deadline for any amended Monell claim. Although the opinion lists a failure-to-intervene claim among Godfrey’s four claims, its analysis and conclusion do not separately state how that claim was resolved.