This article relies on a Barry County record of a September 15, 2023 email thread reviewed by Clutch Justice. The email was sent to attorney Anastase Markou, Christopher J. Elsworth at a Barry County email address, and Julie Nakfoor Pratt at a Barry County email address. The underlying screenshot and record are on file with Clutch Justice.
This article does not assert that the email proves what Pratt or Elsworth read, believed, investigated, or disclosed internally after receipt. It asserts the narrower fact supported by the record: Fuller was raised to both of them in writing before the federal jury verdict in McCann v. Fuller. That written notice triggered Brady and Giglio disclosure obligations. Those obligations were never met. Barry County has never acknowledged they existed.
Barry County records now put a hard date on notice — and a constitutional name on what came after. On September 15, 2023, at 5:03 PM, an email thread titled “BRYAN FULLER” was sent to Christopher J. Elsworth at celsworth@barrycounty.org and Julie Nakfoor Pratt at jpratt@barrycounty.org, with attorney Anastase Markou copied. The message accused Fuller of deliberately mishandling a Barry County defendant’s turn-in while naming Barry County officials as complicit in protecting him. Four days later, a federal jury awarded Ray McCann Jr. $14.5 million against Fuller for constitutional violations including fabricated evidence. Under Brady v. Maryland and Giglio v. United States, the moment that email landed in two Barry County prosecutor inboxes, a constitutional disclosure clock started. It has never been acknowledged. It has never been honored. The affected defendant has never been told it exists. And to this day, Barry County has not admitted any of this happened.
The September 15, 2023 email was sent to both Barry County Prosecutor Julie Nakfoor Pratt and then-Assistant Prosecutor Christopher J. Elsworth at Barry County government email addresses, four days before a federal jury found against Fuller for constitutional violations.
Under Brady v. Maryland and Giglio v. United States, impeachment evidence about a lead detective — including an active wrongful-conviction and fabricated-evidence lawsuit — must be disclosed to the defense. This is not discretionary. It is a constitutional obligation.
The three-part Strickler v. Greene test for a Brady/Giglio violation — favorable evidence, suppressed by the prosecution, material to the outcome — is satisfied here. Fuller’s civil rights exposure was favorable impeachment evidence. It was never disclosed. And Fuller was the documented lead detective in the affected defendant’s case, connected to the very botched turn-in that shaped plea pressure, bond posture, and sentencing.
The new record connects the Fuller disclosure failure to Clutch Justice’s prior reporting on Elsworth, Benjamin Norg, and the Kalamazoo County Prosecutor’s Office — adding a second undisclosed accountability problem to Elsworth’s documented record.
Barry County has never acknowledged that it had written notice of Fuller, that any Brady/Giglio obligation was triggered, or that the affected defendant deserved disclosure. That silence is not a clerical oversight. It is the institution choosing to protect itself over the defendant’s constitutional rights.
The Email Barry County Cannot Unsend
The record reviewed by Clutch Justice shows an email thread dated September 15, 2023, at 5:03 PM. The subject line was “BRYAN FULLER.” The recipients included Anastase Markou, Christopher J. Elsworth, and Julie Nakfoor Pratt. Elsworth and Nakfoor Pratt were reached at their Barry County government email addresses.
The visible message opened with: “Well look at this, BRYAN FULLER!” It included a shortened link. A second visible message in the thread connects Fuller to a botched turn-in and accused Barry County officials of continuing to protect him. It also contained article text and screenshots.
The record does not prove that Elsworth or Nakfoor Pratt clicked the link, opened an internal review, or made a disclosure decision on any cases. It proves something more fundamental: on September 15, 2023, Bryan Fuller was put in writing to both of them as a documented accountability issue tied to an active wrongful-conviction and fabricated-evidence federal lawsuit. That written notice triggered a constitutional obligation under Brady v. Maryland and Giglio v. United States. Neither prosecutor brought Fuller forward as Brady/Giglio material in the affected case record. No disclosure was made. No defendant was notified. The institutional result was not review. It was silence — and silence in the face of a Brady/Giglio obligation is not neutral. It is a violation.
This is not an article about mind-reading. It is an article about a timestamp, a subject line, two county email addresses, a constitutional standard, and what that combination means for the defendant whose case Fuller touched and who has never been told any of this exists.
Why September 15 Matters
By September 15, 2023, McCann v. Fuller was not a hypothetical future credibility issue. Ray McCann Jr.’s federal civil rights lawsuit against MSP Sgt. Bryan Fuller had been pending since December 2019. The case alleged that Fuller fabricated evidence and violated McCann’s constitutional rights in the investigation that helped send an innocent man to prison.
WOOD TV8’s Target 8 had already publicly covered McCann’s civil-rights case before the verdict, including reporting that the exonerated man in the Jodi Parrack case was seeking $12 million from the cold-case detective and later reporting on the depression, paranoia, and personal fallout McCann described after his wrongful conviction. Fuller was not an obscure name buried in a sealed file. His role in a wrongful-conviction case was public, searchable, and serious before the jury ever returned its verdict.
Four days after the Barry County email, on September 19, 2023, a federal jury awarded McCann $14.5 million against Fuller, including punitive damages. Michigan State Police later settled with McCann for $11 million on October 17, 2023. Those settlements made Fuller one of the most consequential police-credibility problems in recent Michigan history. Every case he touched became a potential post-conviction issue. Every prosecutor who had Fuller-connected cases in their files had an obligation to act.
Tap each point to see why the September 15 email changes the constitutional timeline.
McCann Files the Federal Case
McCann v. Fuller was filed in the Western District of Michigan. The case placed Fuller’s alleged fabrication of evidence and constitutional violations into active federal litigation. From this date forward, any prosecutor with a Fuller-connected case had the ability to know about the pending suit.
Fuller Is Raised to Barry County in Writing
The email thread titled “BRYAN FULLER” was sent to Elsworth and Nakfoor Pratt at Barry County email addresses, four days before the federal verdict. This is the moment the Brady/Giglio clock became undeniable. Both prosecutors received written notice naming Fuller in connection with a Barry County criminal matter. Neither disclosed it.
The Jury Awards $14.5 Million — and the Obligation Gets Louder
A federal jury awarded Ray McCann Jr. $14.5 million against Fuller. The credibility issue that had been pending in federal court became a public verdict. At this point, the Brady/Giglio obligation was not diminishing. It was compounding. Every affected defendant now had a constitutional right to know that the detective in their case had just been found liable for fabricating evidence by a federal jury.
MSP Settles for $11 Million
Michigan State Police settled with McCann for $11 million. The state’s decision to pay rather than appeal confirmed the weight of the verdict. For any case involving Fuller’s evidence, reports, texts, or investigative decisions, the disclosure question did not get smaller after this date. It became indefensible to ignore.
The Brady/Giglio Standard Is Not Complicated
There is a reason Barry County has never named this problem out loud. Naming it means owning it. And owning it means acknowledging that a sitting prosecutor and a long-serving APA received written notice of a constitutional problem, did nothing with it, and allowed the affected defendant to proceed through a criminal process built in part on an undisclosed police-credibility crisis.
The legal standard is not obscure. In Brady v. Maryland, the Supreme Court held that suppression by the prosecution of evidence favorable to an accused violates due process where the evidence is material either to guilt or to punishment. In Giglio v. United States, the Court extended that obligation explicitly to impeachment evidence — including information that would allow a defendant to challenge the credibility of a prosecution witness or lead investigator.
In Strickler v. Greene, the Court laid out the three-part test that governs every Brady and Giglio claim. The evidence must be favorable to the accused, either because it is exculpatory or because it is impeaching. It must have been suppressed by the state, either willfully or inadvertently. And it must be material — meaning there is a reasonable probability that, had the evidence been disclosed, the result of the proceeding would have been different.
The three-part Brady/Giglio standard. Applied to the Fuller notice record.
Was the evidence favorable to the accused?
Yes. Fuller was the lead detective connected to the affected defendant’s case, including the botched turn-in. Evidence that the same detective was the subject of an active federal civil rights suit alleging he fabricated evidence — and later, a $14.5 million verdict confirming that a jury found him liable — is textbook Giglio impeachment material. It directly challenged the credibility of a prosecution-aligned actor whose conduct shaped the case. This is the exact category of evidence Brady and Giglio were designed to protect.
Was it suppressed by the prosecution?
Yes. The prosecution received written notice on September 15, 2023, that Fuller was connected to a wrongful-conviction and fabricated-evidence lawsuit. That notice went to two Barry County prosecutor email addresses. Neither the pending suit, the September 19 verdict, nor the October 17 settlement was ever disclosed to the defense in the affected case. Suppression under Brady does not require proof of bad faith. Inadvertent failure to disclose is enough. The failure here was not inadvertent — it followed written notice. But even if it had been inadvertent, the constitutional violation would be the same.
Was it material to the outcome?
Yes. Fuller was not a peripheral figure in the affected defendant’s case. He was the documented lead detective connected to the botched turn-in that shaped the defendant’s arrest, bond posture, plea pressure, and sentencing context. The turn-in failure itself is documented in attorney text records as “incredibly mismanaged” and a likely MSP policy violation. A defendant who knew the lead detective in their case had just been found liable by a federal jury for fabricating evidence in another wrongful-conviction matter would have had powerful, documented grounds to challenge the prosecution’s case, re-examine the plea posture, and pursue post-conviction relief. The reasonable probability standard is not a high bar. It is not a certainty standard. It requires only that the undisclosed evidence could have made a difference. This one would have.
All three elements are met.
The evidence was favorable. Fuller’s wrongful-conviction and fabricated-evidence exposure was impeachment material directly tied to his role in the affected defendant’s case. It was suppressed. No disclosure was ever made, despite written notice to two county prosecutor email addresses. It was material. Fuller’s documented role in the botched turn-in, combined with a federal jury verdict finding him liable for fabricated evidence, created grounds for re-examining every aspect of the case that his conduct touched. Barry County has never acknowledged this analysis exists. The affected defendant has never been told.
Brady and Giglio violations do not require a prosecutor to have personally fabricated anything. They require only that the prosecution suppressed favorable evidence the defense needed to mount a fair challenge. When a prosecutor receives written notice that the lead detective in an active case is the subject of a wrongful-conviction and fabricated-evidence lawsuit — and that information never reaches the defense — the constitutional failure is complete.
Barry County met every element of that failure. It has never said so.
In the Affected Case, Fuller Was Not Background
The documented record makes Fuller central to the affected defendant’s case, not incidental. Text-message records show that the defendant’s attorney identified Fuller as the detective connected to the matter in June 2022, later reported that Fuller confirmed the case was at the prosecutor’s office for review, and confirmed after the arrest that “Fuller is the lead detective.”
The same records document a planned turn-in arrangement. The defendant asked about timing after the arrangement was made. Additional text records with Fuller show discussion of the defendant turning himself in, the expected timing in Barry County, and Fuller saying he would get with the court to find the best time for “in and out.”
Then the arrangement failed. MSP came to the defendant’s home and arrested him in front of his family. The defendant reported that the troopers said there was no turn-in arrangement and that Fuller was no longer on the case. The defense attorney’s response was direct: Fuller “had no idea,” was “in shock,” and said he had updated the records. The attorney also told the defendant the arrest was “unprofessional and incredibly mismanaged,” that it should not have happened because there was an assigned turn-in date and time, and that MSP likely violated its own policy and procedures.
This is not abstract impeachment material about a detective who worked somewhere nearby. Fuller was the lead detective. His conduct — specifically the botched turn-in that the defense attorney described as a likely MSP policy violation — shaped the defendant’s arrest experience, bond situation, plea pressure, and sentencing context from the beginning of the case. The defendant was already living with the consequences of Fuller’s mismanagement when Fuller was simultaneously being sued in federal court for fabricating evidence in another case. And the prosecutors who received written notice that Fuller was a documented constitutional-liability problem chose not to tell the defendant. That choice has consequences. It has had consequences every day since September 15, 2023.
Notice Changes the Disclosure Question — Permanently
Prosecutors are not required to agree with every complaint that lands in their inbox. They are required to take seriously information that may affect the credibility of a lead investigator, the integrity of evidence, or the fairness of a criminal proceeding. That is not a matter of prosecutorial judgment. It is a constitutional floor.
The September 15 email did not merely suggest that Fuller was a person of interest in an unrelated matter. It named him directly, tied him to a Barry County criminal case, and accused him of mishandling the turn-in while county actors protected him. That information, standing alone, was enough to trigger a review. Layered on top of the active McCann v. Fuller litigation alleging fabricated evidence, it was enough to demand one.
Barry County cannot claim it had no reason to scrutinize Fuller. The email puts written notice in two county prosecutor inboxes before the verdict. The verdict itself — a public federal court finding of constitutional violations including fabricated evidence — is not something a sitting prosecutor could miss. The settlement four weeks later confirmed the state’s own assessment of the weight of the evidence against Fuller. Barry County cannot now claim that Fuller was a background figure whose credibility was unknowable, irrelevant, or someone else’s problem. The record says otherwise. The record has always said otherwise. And the defendant in the case Fuller touched has had no opportunity to say any of this to a court, because nobody has ever told them the record exists.
The Judicial Proximity Question
The judge question has to be framed with precision. The fact that Fuller and Judge Michael Schipper lived minutes from each other does not, by itself, prove bias, friendship, communication, or misconduct. But geography is not the whole concern. Fuller and Schipper also spent years operating inside the same small Barry County legal community, where MSP, prosecutors, defense attorneys, probation, and the court repeatedly intersect in the same courthouse ecosystem.
That matters because Fuller was not a random outside witness. He was the lead detective connected to the botched turn-in record in a case before that court, and his credibility was tied to an active wrongful-conviction and fabricated-evidence lawsuit at the time the case moved through plea and sentencing. In a small legal community, a judge presiding over a case involving that detective should disclose any personal, professional, or informal familiarity that could reasonably cause a defendant or the public to question neutrality.
The issue is not “they lived near each other, so the judge was biased.” The issue is whether a judge who worked for years in the same small legal community as the lead detective, and who presided over a case affected by that detective’s conduct, had any relationship, familiarity, communication, or local knowledge that should have been disclosed once Fuller became a documented constitutional-liability problem. That question becomes sharper when the prosecutor’s office had written notice of Fuller, Fuller was documented in the defendant’s turn-in failure, and no one in the system treated any of this as a disclosure issue before plea, sentencing, or post-conviction proceedings moved forward.
Correction Was the Duty. Retaliation Was the Tell.
A prosecutor who learns that the lead detective in a case is simultaneously the subject of an active wrongful-conviction and fabricated-evidence lawsuit has obligations that run in several directions at once. Protect the defendant’s right to a fair process. Protect the court from a misleading record. Protect the public from convictions built on undisclosed police-credibility problems. These obligations do not require the prosecutor to agree with the person raising the alarm. They do not disappear because the warning arrives in an angry email. They do not become optional because the detective is MSP, because the case is politically inconvenient, or because disclosure would make the prosecution harder to defend.
Once Fuller was put in writing to Nakfoor Pratt and Elsworth, the constitutionally required path was not complicated: stop, audit, preserve, disclose, and notify. If Fuller touched the case, defense counsel needed to know — before plea, before sentencing, before any proceeding that Fuller’s conduct might have tainted. After the verdict on September 19, they needed to know that a jury had found against him for fabricating evidence and awarded $14.5 million. After the settlement on October 17, they needed to know that the state paid $11 million to resolve it. None of that happened.
The office could have treated the September 15 email as a trigger for a Brady/Giglio review. It could have notified defense counsel. It could have corrected the record before any post-plea, post-sentencing, or post-conviction proceeding moved forward. Instead, less than a month after the September 15 email, the response from the Barry County system was not review. It was retaliatory prosecution. That sequencing matters. The person raising the Fuller problem in writing was met with charges instead of a transparent case audit. The constitutional obligation created by the notice was buried under the prosecutorial machinery directed at the person who forced the issue into writing. Retaliation does not cure a Brady/Giglio problem. It confirms that the institution understood the stakes and chose protection of itself over honoring the defendant’s constitutional rights.
The Elsworth Problem Did Not Stay in Barry County
Clutch Justice previously reported that Christopher J. Elsworth and Benjamin M. Norg are now both working under Kalamazoo County Prosecutor Jeffrey Getting. Both had personal knowledge of a Barry County plea-agreement dispute. Both are connected to records that have still not been produced. Elsworth denied the existence of plea communications on the Barry County court record in December 2023, despite multiple actors with direct knowledge confirming those communications exist.
The Fuller notice record adds a second lane to the same institutional question. Elsworth was not only an APA involved in the plea-agreement record. He was also one of the two Barry County recipients of a September 15, 2023 written notice about Bryan Fuller, four days before the federal verdict. That means Elsworth carried two separate undisclosed accountability problems into his current role: the denied plea communications and the Fuller Brady/Giglio notice he received but never acted on.
Prosecutor credibility does not reset when an attorney changes counties. If a prosecutor has a documented history of denying the existence of communications that multiple witnesses confirm exist, and a separate written-notice record tying him to an unacknowledged Brady/Giglio obligation, that history belongs to the public record of every matter that prosecutor now handles.
This is the constitutional pathway the new record creates.
What Needs to Happen — and Why It Is Overdue
Barry County should identify every case in which Fuller participated from December 2019 forward, including investigations, turn-ins, evidence handling, witness contacts, probable-cause submissions, and post-conviction proceedings. The review should not be limited to cases where Fuller was the named lead detective. Any meaningful investigative involvement triggers the same Brady/Giglio analysis.
For each case, the county should determine whether the defense was told about McCann v. Fuller, the September 19, 2023 verdict, the October 17, 2023 settlement, and any known internal or external complaints concerning Fuller’s conduct. Where no disclosure was made, defense counsel and affected defendants should be notified now. That notification cannot be limited to pending cases. Defendants who pleaded, were sentenced, abandoned appeals, or accepted probation terms without knowing the detective’s active wrongful-conviction exposure were deprived of information the Constitution required them to have. The obligation to correct that deprivation does not expire with the sentence.
Kalamazoo County Prosecutor Jeffrey Getting should answer publicly whether his office has reviewed Elsworth’s Barry County record, including the December 2023 plea-communications denial and the September 15, 2023 Fuller notice, before allowing him to continue handling matters involving people’s liberty, families, and constitutional rights.
This is not merely a Bryan Fuller story, a prosecutor-misconduct story, or a wrongful-conviction story. It is a Brady/Giglio story that Barry County has been suppressing since September 15, 2023. The affected defendant has a constitutional right to know that the lead detective in their case was the subject of an active wrongful-conviction lawsuit at the time the case was moving, that a federal jury found that detective liable for fabricating evidence four days after the prosecutorial notice was received, and that the state of Michigan paid $11 million to settle the fallout. They have never been told. Barry County has never admitted the obligation existed. That combination — notice, silence, and the choice to punish the person who forced the issue into writing — is not a clerical failure. It is a constitutional one, and it belongs in the record.
Sources and Records Reviewed
Barry County RecordEmail thread titled “BRYAN FULLER,” dated September 15, 2023, 5:03 PM, sent to Anastase Markou, Christopher J. Elsworth, and Julie Nakfoor Pratt. Screenshot and Barry County record on file with Clutch Justice.
Case ExhibitText-message records between the affected defendant and defense counsel, June 2022 through January 2023, documenting Fuller’s role, the turn-in arrangement, the home arrest, and counsel’s statements that Fuller was the lead detective and that the arrest was mismanaged.
Case ExhibitText-message records with Detective Bryan Fuller regarding the planned Barry County turn-in, timing, court coordination, and record updates.
MSP ComplaintMarch 26, 2023 email to MSP Internal Affairs requesting investigation of the botched turn-in involving Detective Bryan Fuller.
Federal CaseMcCann v. Fuller, Case No. 1:19-cv-01032, U.S. District Court for the Western District of Michigan; jury verdict entered September 19, 2023; settlement reported October 17, 2023.
Legal StandardBrady v. Maryland, 373 U.S. 83 (1963); Giglio v. United States, 405 U.S. 150 (1972); Strickler v. Greene, 527 U.S. 263 (1999).
Public ReportingWOOD TV8 Target 8, “Exonerated man in Jodi Parrack case seeks $12 million from cold case detective.” woodtv.com/news/target-8/exonerated-man-in-jodi-parrack-case-seeks-12-million-from-cold-case-detective/
Public ReportingWOOD TV8 Target 8, “Exonerated man: Depression, paranoia after wrongful conviction.” woodtv.com/news/target-8/exonerated-man-depression-paranoia-after-wrongful-conviction/
Prior CoverageRita Williams, “The Detective Who Was Found Guilty of Violating Someone’s Constitutional Rights. He Was Still Working Cases.” Clutch Justice, June 24, 2026. clutchjustice.com/2026/06/24/bryan-fuller-michigan-state-police-wrongful-conviction/
Prior CoverageRita Williams, “Two Attorneys With Personal Knowledge of a Barry County Plea Agreement Are Now Working Under the Same Kalamazoo County Prosecutor. Neither Is Talking.” Clutch Justice, June 20, 2026, updated June 25, 2026. clutchjustice.com/2026/06/20/barry-county-elsworth-norg-kalamazoo/
Bluebook: Williams, Rita. Barry County Prosecutors Were Alerted of MSP Bryan Fuller Four Days Before the Wrongful Conviction Verdict, Clutch Justice (June 29, 2026), https://clutchjustice.com/2026/06/29/barry-county-pratt-elsworth-fuller-written-notice/.
APA 7: Williams, R. (2026, June 29). Barry County prosecutors were alerted of MSP Bryan Fuller four days before the wrongful conviction verdict. Clutch Justice. https://clutchjustice.com/2026/06/29/barry-county-pratt-elsworth-fuller-written-notice/
MLA 9: Williams, Rita. “Barry County Prosecutors Were Alerted of MSP Bryan Fuller Four Days Before the Wrongful Conviction Verdict.” Clutch Justice, 29 June 2026, clutchjustice.com/2026/06/29/barry-county-pratt-elsworth-fuller-written-notice/.
Chicago: Williams, Rita. “Barry County Prosecutors Were Alerted of MSP Bryan Fuller Four Days Before the Wrongful Conviction Verdict.” Clutch Justice, June 29, 2026. https://clutchjustice.com/2026/06/29/barry-county-pratt-elsworth-fuller-written-notice/.
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