581 F. App'x 509
6th Cir.2014Background
- Martin was prosecuted for burglary based on statements by Wheeler and Tim Martin; grand jury indictment established probable cause; Marmet failed to interview Martin or alibi witnesses; prosecutors terminated case due to lack of evidence; Martin was tried and acquitted; district court dismissed her § 1983 claims and declined supplemental jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause after grand jury indictment | Martin argues probable cause lacked due to withheld exculpatory evidence | Indictment itself proves probable cause; no duty to withhold exculpatory evidence once indicted | Probable cause established by indictment; claim fails |
| Monell claim without underlying constitutional violation | Monell liability exists despite no single constitutional violation | No Monell liability without a constitutional violation by an employee | Monell claim fails; no underlying federal violation |
Key Cases Cited
- Sykes v. Anderson, 625 F.3d 294 (6th Cir. 2010) (elements of malicious prosecution)
- Robertson v. Lucas, 753 F.3d 606 (6th Cir. 2014) (grand jury indictment establishes probable cause, with exception)
- United States v. Angel, 355 F.3d 462 (6th Cir. 2004) (no duty to provide exculpatory evidence to grand jury)
- Ahlers v. Schebil, 188 F.3d 365 (6th Cir. 1999) (police not required to investigate further after probable cause established)
- Moldowan v. City of Warren, 578 F.3d 351 (6th Cir. 2009) (Monell liability must be tied to underlying constitutional violation; footnote discussed)