Fifth Circuit: George Alvarez v. City of Brownsville

Insufficient connection between municipality's policies and the withholding of the evidence in this case; placing sole discretion in a single officer does not amount to deliberate indifference, and the officer's conduct was no worse than negligent.

Deft did not have a constitutional right to pre-plea-deal disclosure of exculpatory evidence in the possession of the government.  

Concurrence: Federal District Court had obligation to allow challenges to potentially doctored pieces of evidence.

Concurrence: Brady is a trial right, waiveable at plea stage.

Dissent: Constitutional right.


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