Andrea Miller v. Woodston Maddox
866 F.3d 386
| 6th Cir. | 2017Background
- Andrea Miller was arrested, charged, and indicted for reckless driving and resisting arrest based on Officer Woodston Maddox’s statements and affidavit.
- Maddox swore an affidavit that Miller ran a stop sign, sped, became confrontational, and resisted removal from her vehicle; the night commissioner issued an arrest warrant and bound the case over after Maddox’s preliminary-hearing testimony.
- Miller sued Maddox under 42 U.S.C. § 1983 for malicious prosecution under the Fourth Amendment, alleging Maddox knowingly/recklessly made false statements that set the prosecution in motion.
- The district court granted Maddox summary judgment, reasoning an indictment conclusively establishes probable cause and that Maddox had absolute immunity for his hearing testimony.
- On appeal the Sixth Circuit held (1) Maddox influenced the prosecution by filing the affidavit and being the only witness at the preliminary hearing; (2) under King v. Harwood Miller could rebut the presumption of probable cause because Maddox’s false statements in pre-grand-jury proceedings were material; (3) genuine disputes exist about probable cause and post-process deprivation of liberty (pretrial supervision and delay); (4) Maddox is not entitled to absolute or qualified immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Maddox participated in the decision to prosecute | Miller: Maddox filed the affidavit and was the only witness at the preliminary hearing, thus aided the prosecution decision | Maddox: Did not directly contact prosecutor; testimony alone is immune | Held: Maddox influenced/participated by swearing affidavit and testifying at preliminary hearing; participation satisfied Sykes standard |
| Whether indictment conclusively establishes probable cause for malicious prosecution | Miller: King exception allows rebuttal where officer knowingly/recklessly made material false statements in affidavits/reports that set prosecution in motion | Maddox: Indictment and preliminary-hearing binding establish probable cause; prior testimony immune | Held: King exception applies; indictment is rebuttable because false affidavit/testimony were material and not limited to grand-jury testimony |
| Whether there was probable cause for the charged offenses | Miller: Maddox admits key statements (no speeding; no physical resistance) so probable cause lacking; dash-cam raises dispute about stop-sign observation | Maddox: Claims probable cause shown at preliminary hearing and indictment; waives some arguments on appeal | Held: Genuine issues of material fact exist as to probable cause for reckless driving and resisting arrest; summary judgment improper |
| Whether Maddox is immune (absolute or qualified) | Miller: No absolute immunity for false affidavits; qualified immunity is unavailable for fabricating evidence that initiates prosecution | Maddox: Testimonial immunity and lack of clearly established law shield him | Held: No absolute immunity for false warrant affidavits; qualified immunity denied because clearly established Fourth Amendment right not to be seized/prosecuted on fabricated evidence |
Key Cases Cited
- King v. Harwood, 852 F.3d 568 (6th Cir. 2017) (creates exception allowing rebuttal of presumption that indictment establishes probable cause when officer knowingly/recklessly falsifies material pre-grand-jury statements)
- Sanders v. Jones, 845 F.3d 721 (6th Cir. 2017) (discusses limits of absolute immunity and that false police reports generally do not defeat indictment presumption)
- Sykes v. Anderson, 625 F.3d 294 (6th Cir. 2010) (elements of Fourth Amendment malicious prosecution claim)
- Rehberg v. Paulk, 566 U.S. 356 (2012) (absolute immunity for grand jury testimony but distinguishes pre-testimony acts like falsifying affidavits)
- Briscoe v. LaHue, 460 U.S. 325 (1983) (absolute immunity for witness testimony at trial)
- Kalina v. Fletcher, 522 U.S. 118 (1997) (no absolute immunity for falsified affidavit statements used to obtain warrants)
- Malley v. Briggs, 475 U.S. 335 (1986) (qualified immunity for officers making false statements in affidavits)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified-immunity framework)
- Spurlock v. Satterfield, 167 F.3d 995 (6th Cir. 1999) (fabrication of evidence and malicious prosecution violate clearly established Fourth Amendment rights)