Aaron Salter v. City of Detroit, Mich.
133 F.4th 527
6th Cir.2025Background
- Aaron Salter was wrongfully convicted of murder in 2003 based solely on an eyewitness identification from a single mug shot, with no physical or other corroborating evidence.
- The police, specifically Detective Olsen, presented the eyewitness (Luster) with only Salter’s mug shot, contrary to department policy, and told Luster that police "picked up" one shooter, making the identification suggestive.
- After Salter’s conviction, evidence came to light that the witness had also identified another suspect (Collins) and that this was not disclosed to defense; additionally, Luster later recanted his identification.
- After 15 years in prison, Salter’s conviction was vacated by stipulation due to newly discovered evidence, and he was released.
- Salter subsequently filed a § 1983 civil rights suit against Detective Olsen for failure to disclose exculpatory evidence (Brady claim) and for conducting a highly suggestive identification procedure, resulting in an unfair trial.
- The district court denied summary judgment on qualified immunity grounds, leading to this interlocutory appeal by Detective Olsen.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Brady Violation (Withholding Evidence) | Olsen withheld evidence that another suspect was ID’d | Evidence was not withheld or was otherwise available | Jury could find a Brady violation; claim proceeds |
| Suggestive Identification Process | One-photo ID was unduly suggestive and unreliable | Procedure allowed; witness knew Salter independently | Procedure was unduly suggestive, not reliable |
| Clearly Established Right (Brady/ID) | Law was clearly established barring conduct | Not clearly established for police in 2003 | Law was clearly established; no qualified immunity |
| Collateral Estoppel (ID claim precluded) | Prior criminal rulings should not preclude claim | State court’s prior ruling precludes this challenge | Vacated convictions have no preclusive effect |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecutors must disclose material exculpatory evidence to defense)
- Stovall v. Denno, 388 U.S. 293 (1967) (single-person show-ups are highly suggestive; courts must assess fairness based on totality of circumstances)
- Manson v. Brathwaite, 432 U.S. 98 (1977) (factors to determine reliability of eyewitness identification following suggestive procedures)
- Simmons v. United States, 390 U.S. 377 (1968) (unnecessarily suggestive identification procedures risk misidentification)
- Heck v. Humphrey, 512 U.S. 477 (1994) (doctrine limits § 1983 claims challenging conviction unless conviction was favorably terminated)
- Neil v. Biggers, 409 U.S. 188 (1972) (reliability test for eyewitness identification)