Anthony Spencer v. County of Huron
17-1190
| 6th Cir. | Nov 22, 2017Background
- In 2013 Spencer was arrested and prosecuted based on confidential informant Tracey Champagne’s account of multiple controlled heroin buys; Champagne had prior experience as an informant and was searched and given buy money for the buys.
- Spencer was detained based on tips and testimony; after preliminary examinations a state judge found probable cause to bind him over on three felony drug charges.
- Months later Spencer’s cousin and Spencer himself (via a passed polygraph) disputed the informant’s account; prosecutors dismissed the charges.
- Spencer sued under 42 U.S.C. § 1983 (Fourth Amendment claims for false arrest and malicious prosecution) and raised state-law claims; defendants moved for summary judgment.
- The district court granted summary judgment on federal claims, applying collateral estoppel based on the state court’s probable-cause finding, declined supplemental jurisdiction over state claims, and denied Spencer’s motion to enlarge the record; Spencer appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether collateral estoppel bars Spencer’s Fourth Amendment false-arrest and malicious-prosecution claims | Spencer: preliminary hearing relied on materially false statements by officers (they later admitted not actually seeing Spencer), so he may relitigate probable cause | Defendants: Spencer offers no record evidence that officers made materially false statements; state-court probable cause stands | Affirmed: collateral estoppel applies; Spencer failed to cite evidence showing materially false statements |
| Whether Monell claim against Huron County survives summary judgment | Spencer: County’s alleged failure to evaluate/train officers supports municipal liability | Defendants: Monell requires an underlying constitutional violation | Affirmed: Monell claim fails because no underlying § 1983 violation remains |
| Whether district court properly declined supplemental jurisdiction over state-law claims | Spencer: state-law claims are valid and should proceed | Defendants: federal claims dismissed, so district court should decline supplemental jurisdiction | Affirmed: court properly declined jurisdiction and dismissed state claims without prejudice |
| Whether district court abused discretion denying motion to enlarge the record for newly discovered retaliatory statements | Spencer: newly discovered retaliatory statements by Swartz would show false/malicious arrest | Defendants: Spencer provided no evidence or record citations; motive is irrelevant to probable cause | Affirmed: denial was not an abuse of discretion; no evidentiary showing that new material would change probable-cause finding |
Key Cases Cited
- Hinchman v. Moore, 312 F.3d 198 (6th Cir. 2002) (state-court judgments get preclusive effect under state law; collateral estoppel elements explained)
- Darrah v. City of Oak Park, 255 F.3d 301 (6th Cir. 2001) (officer-supplied false information at prior proceeding can defeat issue preclusion)
- Migra v. Warren City Sch. Dist. Bd. of Educ., 465 U.S. 75 (1984) (federal courts must give state-court judgments the same preclusive effect they have under state law)
- Gregory v. City of Louisville, 444 F.3d 725 (6th Cir. 2006) (Monell liability requires an underlying constitutional violation)
- McCurdy v. Montgomery Cty., Ohio, 240 F.3d 512 (6th Cir. 2001) (probable cause inquiry is objective; subjective officer motive is irrelevant)