James Dawson v. John Dorman
528 F. App'x 450
6th Cir.2013Background
- Dawson was suspected of robbing Eva Morrow at gunpoint and was indicted for first-degree robbery.
- The indictment was dismissed on the eve of trial due to witness credibility concerns.
- Dawson sued lead investigator Dorman under 42 U.S.C. § 1983 for false arrest and malicious prosecution, plus supervisors and the city for state and federal law violations.
- Dorman allegedly provided false or misleading information to obtain the warrant, lied at preliminary hearing, and lied before the grand jury.
- The district court granted summary judgment on Dawson's federal claims and declined to hear state-law claims; Dawson appealed.
- On appeal, the court affirmed the judgment largely for the district court’s reasons but addressed an error: Dorman’s fingerprint-form misstatement and grand-jury testimony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether credibility disputes bar summary judgment on malicious-prosecution claim | Dorman’s past dishonesty and intentional misrepresentations create a genuine credibility dispute that should go to trial. | There is no evidence of deliberate falsity; credibility disputes do not defeat summary judgment where no proof of bad faith or reckless disregard exists. | Credibility issues exist, but the misstatement was not shown to be critical to probable cause; summary judgment affirmed. |
| Whether Dorman’s fingerprint misstatement was essential to probable cause and the prosecutor’s decision | The erroneous fingerprint account and grand-jury testimony influenced probable cause and the decision to proceed. | Identification by Eva and fingerprint evidence would have supported probable cause; misstatement alone was not decisive. | The misstatement was not essential to probable cause or the prosecutor’s decision; judgment upheld. |
Key Cases Cited
- Sykes v. Anderson, 625 F.3d 294 (6th Cir. 2010) (malicious-prosecution elements and causation guidance)
- Ahlers v. Schebil, 188 F.3d 365 (6th Cir. 1999) (probable-cause analysis in false-arrest context)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (S. Ct. 1986) (summary-judgment standard and credibility assessment limits)
- Celotex Corp. v. Catrett, 477 U.S. 317 (S. Ct. 1986) (nonmoving party must go beyond pleadings)
- Dugan v. Smerwick Sewerage Co., 142 F.3d 398 (7th Cir. 1998) (credibility disputes alone do not preclude summary judgment)
- TypeRight Keyboard Corp. v. Microsoft Corp., 374 F.3d 1151 (Fed. Cir. 2004) (summary judgment not denied where credibility is only issue)
- Springer v. Durflinger, 518 F.3d 479 (7th Cir. 2008) (credibility disputes require independent evidence)
- Nelms v. Wellington Way Apartments, LLC, 2013 WL 408034 (6th Cir. 2013) (not included in official reporter citations; cited for credibility discussion)