Ronnie Qualls was convicted in 1993 of murdering brothers Ronald "Dallas" Price and Roosevelt "Tony" Price, who were shot near Harrison Avenue in Boston in the early morning hours of October 3, 1992. The Supreme Judicial Court of Massachusetts later ordered a new trial on hearsay grounds, and a second jury convicted Qualls again in 1998. More than two decades later, in 2020, the Massachusetts Superior Court vacated those 1998 convictions by granting Qualls' joint motion for a new trial based on newly discovered evidence. The Commonwealth then entered a nolle prosequi, and Qualls was released. He subsequently sued four former BPD officers — Clifton Haynes, John Harden, Dennis Harris, and Daniel Keeler — under 42 U.S.C. § 1983 and the Massachusetts Civil Rights Act, alleging they violated his due process rights by suppressing exculpatory evidence, using unconstitutional photo arrays, and coercing eyewitnesses.
U.S. District Judge George A. O'Toole Jr. of the District of Massachusetts granted summary judgment for all four defendants on March 31, 2026, holding that Qualls failed to show the unlawfulness of the defendants' conduct was clearly established at the time it occurred — the second prong of the qualified immunity analysis. Because Qualls failed that step, the court did not reach the first prong of whether a constitutional violation occurred.
The core of Qualls' claim against detectives Harris and Keeler centered on a bloodstained sweatshirt worn by James Earl "Junior" Williams, a suspect stopped near the crime scene the morning of the shooting. Harris collected the sweatshirt and submitted it for forensic testing; the crime lab identified Group B human blood in the stains, the same blood type shared by Williams and both Price brothers. No further testing was conducted. Qualls argued that Harris and Keeler engaged in what he called investigative suppression by abandoning the forensic inquiry after receiving those results, contending that additional serological testing could have exculpated him.
Judge O'Toole rejected that theory on multiple grounds, addressing why the cited precedents did not clearly establish the unlawfulness of the conduct. Applying Kyles v. Whitley and Arizona v. Youngblood, the court held that Qualls' Brady argument lacked a necessary factual predicate: the favorable, material evidence he claimed was suppressed never actually existed. Because the crime lab report was disclosed and used by defense counsel at trial, there was no suppression of existing evidence. As for the failure to conduct additional testing, the court relied on Youngblood's holding that the police have no constitutional duty to perform any particular investigatory test, and on First Circuit precedent establishing that the failure to create exculpatory evidence does not constitute a Brady violation.
On the photo array claim, Qualls argued that Harris and Keeler violated his rights by including his photograph in arrays shown to witnesses despite what he characterized as overwhelming evidence pointing to Williams. The court held that Qualls identified no authority establishing that the mere inclusion of his photograph in an array rendered it impermissibly suggestive, and noted that First Circuit precedent from the relevant period expressly permitted police to base a photo array on suspicion regarding a particular defendant.
Qualls' third theory — that Keeler bribed or coerced witnesses by driving them to court to remove pending court-issued defaults — also failed. The court noted that the assistant district attorney had disclosed the rides to the Superior Court and to defense counsel in open court during the murder trial, and that Qualls never identified what testimony he claimed was induced or coerced, or any portion of the record showing Keeler suppressed evidence of the arrangement or used it to procure false testimony. Because the same qualified immunity analysis applies to claims under the Massachusetts Civil Rights Act, the court granted summary judgment on that count as well.