42 USC § 1983; Fourth Amendment; Statute of limitations; Accrual; Discovery rule; Unreasonable seizure; Unreasonable search; Excessive force; Brady v Maryland violation; Materiality; Pretrial dismissal of charges; Sua sponte dismissal; Child’s claims

The court held that plaintiff-mother’s Fourth Amendment claims against defendant-officer were time-barred, that her Brady claim against defendant-municipality failed because the criminal charges were dismissed before trial, and that the district court improperly dismissed the child’s Fourth Amendment claims against the officer sua sponte. Plaintiffs sued under § 1983 after a traffic stop, arrest, vehicle search, and delayed disclosure of dispatch tapes allegedly contradicting the officer’s preliminary-exam testimony. The district court dismissed the complaint. On appeal, the court held that the one-year limitations period for the mother’s Fourth Amendment claims began at the traffic stop even under the discovery rule because she knew of “her injuries and their cause” when the arrest, search, and force occurred. It noted that her own allegations that she followed traffic laws and stopped immediately gave her reason to investigate, and the discovery rule does not wait until a plaintiff has “enough evidence to win the case[.]” The court next held that the Brady claim failed because Brady generally protects a “trial-related” disclosure right and requires materiality measured by whether suppressed evidence would have produced a different trial result. Because prosecutors dismissed the criminal case before trial, the alleged delay caused “serious hardships” but not the type of injury Brady remedies. Finally, the court held that the district court abused its discretion by dismissing the child’s Fourth Amendment claims against the officer without notice because the officer had moved to dismiss only the mother’s claims, and the child received no “chance to either amend his complaint or respond[.]” Affirmed in part, reversed in part, and remanded.