Brady Offense No. 1767976319 - 1265060234

This submission requests the review and placement of Jonathan Ross, an agent of U.S. Immigration and Customs Enforcement (ICE), on the Brady/Giglio disclosure list maintained by the appropriate prosecuting authority. This request arises from Agent Ross’s involvement in the fatal shooting of Renee Good in Minneapolis, Minnesota. The incident resulted in the death of Ms. Good and has generated serious and substantiated concerns regarding Agent Ross’s credibility, judgment, and compliance with constitutional and agency use-of-force standards.

Agent Ross discharged his firearm during the encounter that killed Renee Good. Available evidence, including witness statements and contemporaneous reporting, contradicts material aspects of Agent Ross’s account of the events leading to the shooting. These contradictions relate directly to the necessity and proportionality of the use of deadly force, as well as the accuracy and completeness of Agent Ross’s post-incident statements. Such discrepancies constitute classic impeachment material bearing directly on truthfulness and reliability as a witness.

The circumstances of the shooting indicate potential violations of established law-enforcement use-of-force principles and ICE policy, including the requirement that lethal force be employed only when objectively reasonable and necessary to prevent imminent death or serious bodily harm. The fatal outcome, coupled with disputed factual assertions by Agent Ross, raises substantial doubt as to his ability to provide credible testimony in any criminal proceeding. These doubts are not speculative; they arise from the incident itself and from the divergence between Agent Ross’s statements and other available evidence.

As a result of this shooting, Agent Ross is subject to investigation and scrutiny that constitutes impeachment material under Brady v. Maryland and Giglio v. United States. Any administrative, civil, or criminal inquiry stemming from the killing of Renee Good directly impacts Agent Ross’s credibility and must be disclosed to defendants in cases where he may testify. Failure to flag Agent Ross as a Brady/Giglio officer would risk unconstitutional nondisclosure and undermine the integrity of prosecutions relying on his testimony.

This request does not depend on the final disposition of any investigation. The constitutional obligation to disclose impeachment evidence attaches when information tends to call a witness’s credibility into question, not when wrongdoing has been conclusively adjudicated. Given that Agent Ross used deadly force resulting in the death of Renee Good under contested circumstances, his placement on the Brady/Giglio list is required to ensure compliance with due process and prosecutorial ethical duties.