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Opinion

govinfo:USCOURTS-ctd-3_24-cv-01336-1

U.S. District Court for the District of Connecticut · 2026-06-17

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UNITED STATES DISTRICT COURT 
DISTRICT OF CONNECTICUT 
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24-cv-1336 (SFR) 
CHARLES C. WILLIAMS, 
 
Plaintiff, 
 
v. 
 
CITY OF HARTFORD, ET AL., 
 
Defendants. 
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MEMORANDUM & ORDER 
Before the Court is Defendants’ Motion for Reconsideration, ECF No. 50, of the 
Memorandum and Order (“Opinion”) denying Defendant’s Motion to Dismiss, ECF No. 49. 
For the reasons stated below, the Motion for Reconsideration is granted in part and denied in 
part, and I decline to alter the holding of the Opinion. 
I. FACTS AND PROCEDURAL HISTORY 
I assume familiarity with the facts of this case and will address only the facts and 
procedural history relevant to the Motion for Reconsideration. 
On August 20, 2024, Williams filed a Complaint alleging, inter alia , that several 
Hartford Police officers improperly suppressed exculpatory evidence during Williams’ 
criminal trial, namely a sworn statement from the complainant and a police report, in violation 
of Williams’ due process rights under Brady v. Maryland, 373 U.S. 83 (1963). Compl., ECF 
No. 1. The Complaint named two sets of Defendants : the City of Hartford (“City”) and the 
Individual Defendants, all of whom were public safety personnel in the Hartford Police and 
Fire Departments. 

2 
The City filed a Motion to Dismiss the original Complaint. ECF No. 29 . While 
recognizing that police officers can be liable for Brady violations under § 1983 when they 
withhold exculpatory evidence from prosecutors, the City argued that it could not be liable to 
the extent that Williams asserted that officers failed to provide exculpatory materials directly 
to him or his counsel. Id. at 20-21. 
On February 7, 2025, Williams filed an Amended Complaint clarifying that certain 
officers improperly withheld exculpatory evidence by failing to provide materials to the 
prosecutor.1 Am. Compl., ECF No. 30. In particular, the Amended Complaint alleges that two 
documents were not “handed over to prosecutors in the State’s Attorney’s Office, let alone 
Plaintiff and his attorneys.” Id. ¶ 61; see also id. ¶ 62 (alleging that the documents were “never 
provided to prosecutors or the defense”). Thereafter, the City filed a Supplemental 
Memorandum in Support of its Motion to Dismiss, addressing the Amended Complaint, ECF 
No. 33, and Individual Defendants moved to dismiss the Amended Complaint, ECF No. 34. 
At oral argument on the Motions to Dismiss on January 22, 2026 , counsel for the 
Individual Defendants stated: 
I will state that given your Honor’s questioning of [the City’s attorney] 
concerning the amendment of the complaint to include a failure to disclose to 
the state prosecutor’s office the alleged exculpatory material, it likely cures that 
defect and we will probably need to address that by way of summary judgment 
later on down the line. 
ECF No. 56, at 25. 
 
1 The “factual allegations” section of Williams’ original Complaint alleged that officers never 
provided this exculpatory evidence to Williams or his attorney and did not mention a failure to 
provide the materials to prosecutors. Compl. ¶¶ 57 -58. However, Counts 1 and 2 of the original 
Complaint stated that the evidence was never turned over to “ the State’s Attorney or the 
Connecticut Superior Court or to the Plaintiff during his criminal proceedings.” See id. at 12-13. 

3 
On February 5, I granted in part and denied in part the Motions to Dismiss. ECF No. 
49. On the issue of qualified immunity for the alleged Brady violations, I noted: 
At oral argument, counsel for the Individual Defendants conceded that they 
were abandoning their qualified immunity claims with respect to Counts 1, 2, 
and 3 at this stage of the proceedings, after Williams amended his Complaint to 
allege that the Individu al Defendants failed to share exculpatory information 
with the prosecutor. 
ECF No. 49, at 7 n.4. Because I understood the Individual Defendants to have conceded that 
Williams had pleaded sufficient facts for the Brady violations alleged in Counts 1, 2, and 3 to 
proceed to the summary judgment stage, I provided no additional consideration of either the 
City’s or the Individual Defendant’s arguments on this point. 
On February 11, 2026, Defendants filed the instant Motion for Reconsideration of the 
Opinion. ECF No. 50. In th e Motion for Reconsideration , Defendants assert the same 
arguments they made in t he Motions to Dismiss: namely, that the Individual Defendants are 
entitled to qualified immunity to the extent Williams faults them for failing to provide 
exculpatory evidence directly to him as “ it was not clearly established at the time of the 
challenged conduct in 2014 , that the Individual Defendants were required to disclose to 
Plaintiff and his counsel, rather than to prosecutors or the court.” ECF 50-1, at 3. Defendants 
further argue: 
Individual Defendants did not concede [at oral argument] that qualified 
immunity did not bar the Plaintiff’s claims that are based upon the theory that 
Brady material was improperly withheld from the plaintiff and his defense 
counsel. Rather, at argument counsel conceded that by adding the allegation that 
the Defendants failed to turn over alleged Brady material to the prosecutors that 
plaintiff had stated a cause of action, and the individual Defendants would not 
pursue their Motion to Dismiss Counts 1, 2 and 3 on that basis. 
Id. at 4-5 (emphasis in original). 

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Thereafter, I convened a status conference with the parties on June 1, 2026 . At the 
conference, Williams’ counsel confirmed on the record that Williams is pursuing Brady claims 
based on the alleged failure of Individual Defendants to provide exculpatory material to the 
prosecutors. Counsel confirmed that Williams is not pursuing any claim based on an alleged 
failure by Individual Defendants to provide exculpatory materials directly to Williams or his 
defense counsel. 
II. LEGAL STANDARD 
Local Rule of Civil Procedure 7(c) permits a party to file a motion for reconsideration 
within seven days of the filing of the decision from which the party seeks relief. D. Conn. 
Local R. Civ. P. 7(c). The Second Circuit has repeatedly held that “[t]he standard for granting 
. . . a motion [for reconsideration] is strict.” Shrader v. CSX Transp., Inc. , 70 F.3d 255, 257 
(2d Cir. 1995). A motion for reconsideration “will generally be denied unless the [movant] can 
point to controlling decisions or data that t he court overlooked—matters, in other words, that 
might reasonably be expected to alter the conclusion reached by the court.” Id. Courts have 
granted motions for reconsideration in limited circumstances, including: (1) where there has 
been an “intervening change of controlling law”; (2) where new evidence has become 
available; or (3) where there is a “need to correct a clear error o r prevent manifest injustice.” 
Virgin Atl. Airways, Ltd. v. Nat’l Mediation Bd., 956 F.2d 1245, 1255 (2d Cir. 1992) (internal 
quotation marks omitted). A motion for reconsideration is “not a vehicle for relitigating old 
issues, presenting the case under new theories, securing a rehearing on the merits, or otherwise 
taking a second bite at the apple.” Analytical Surv.s, Inc. v. Tonga Partners, L.P., 684 F.3d 36, 
52 (2d Cir. 2012) (citation and internal quotation marks omitted). “Such motions must be 
narrowly construed and strictly applied in order to discourage litigants from making repetitive 

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arguments on issues that have been thoroughly considered by the court.” Range Road Music, 
Inc. v. Music Sales Corp., 90 F. Supp. 2d 390, 391-92 (S.D.N.Y. 2000). 
III. DISCUSSION 
To survive a motion to dismiss for failure to state a claim pursuant to Fed. R. Civ. P. 
12(b)(6), a complaint must contain “sufficient factual matter, accepted as true, to ‘state a claim 
to relief that is plausible on its face.’” Ashcroft v. Iqbal , 556 U.S. 662, 678 (2009); Kim v. 
Kimm, 884 F.3d 98, 103 (2d Cir. 2018); Lapaglia v. Transamerica Cas. Ins. Co., 155 F. Supp. 
3d 153, 155 (D. Conn. 2016). 
Defendants do not argue in their Motion for Reconsideration that Counts 1, 2 and 3 
should have been dismissed in their entirety. Rather, Defendants instead ask me to 
reconsider [my] Decision and clarify that the claims set forth in Counts 1, 2 or 
3 based solely on the allegations of failing to disclose to the prosecutors or the 
court are the only claims that may proceed, and that the remainder of the claims 
based on a failure to disclose to the plaintiff and his counsel are dismissed under 
the theory of qualified immunity. 
ECF No. 50-1, at 5. 
As confirmed at the status conference, Williams is not advancing a Brady claim based 
on an alleged failure of any Individual Defendant to provide exculpatory material to Williams 
or his counsel. 2 To the extent that the Motion for Reconsideration explains that Individual 
Defendants did not intend to abandon an argument on this point at oral argument and seeks 
this clarification on the scope of Williams’ claims, the Motion is granted. 
 
2 Of course, had Individual Defendants provided the exculpatory materials directly to Williams or 
his counsel, the information would not have been suppressed in violation of Brady and Williams 
could have made use of it at trial. However, this point is not relevant to whether police officers 
had a duty to provide this information directly to Williams or his counsel. 

6 
Nonetheless, Williams’ Brady claims are sufficient to overcome qualified immunity at 
this motion-to-dismiss stage because the Amended Complaint alleges that certain Individual 
Defendants failed to share exculpatory information with prosecutors during Williams’ criminal 
trial. See Am. Compl. ¶¶ 61-62, 71, 76, 83. To the extent that Defendants’ Motion asks me to 
alter the Opinion’s holding denying the motion to dismiss Counts 1, 2, and 3—or to effectively 
strike parts of the Amended Complaint—I decline to do so. 
IV. CONCLUSION 
The Motion for Reconsideration, ECF No. 50, is therefore granted in part and denied 
in part. 
SO ORDERED. 
 
New Haven, Connecticut 
June 17, 2026 
/s/Sarah F. Russell 
SARAH F. RUSSELL 
United States District Judge 
 
 
 

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