Background
Plaintiffs Marvin Cotton and Anthony Legion spent nearly twenty years in prison for murder convictions that were vacated in 2020 after evidence emerged suggesting key witness testimony was fabricated and material evidence was withheld. The Plaintiffs sued Detroit Police Department Investigator Donald Hughes and Sergeant Walter Bates, alleging violations of the Brady rule, malicious prosecution, and fabrication of evidence. The district court denied the officers’ motion for summary judgment on several claims but granted it on others, leading to this appeal regarding the denial of qualified immunity.
The court’s reasoning
The court analyzed its interlocutory jurisdiction under the collateral order doctrine and pendent appellate jurisdiction. It determined that Heck doctrine arguments and challenges to the admissibility of hearsay evidence fall outside the scope of immediate appeal. Regarding qualified immunity, the court found that the officers waived arguments concerning clearly established law and forfeited arguments regarding bad faith. On the merits of the claims within jurisdiction, the court held that vacated convictions do not trigger collateral estoppel, and genuine disputes of material fact regarding the officers’ knowledge of fabricated testimony and withheld evidence precluded summary judgment.
What it means going forward
The decision allows the civil rights claims against the officers to proceed to trial on the issues of Brady violations, malicious prosecution, and fabrication of evidence, while dismissing the officers’ attempt to resolve the case on interlocutory appeal regarding the Heck doctrine and factual disputes.
Podcast (federal-narrative-summaries): Play in new window | Download