John Sampson v. Lisa Gee-Cram, 655 F. App'x 383

Background

Dr. John Sampson (and related entities: Argyle, a pension fund, Fourth Street) were audited by Blue Cross Blue Shield of Michigan (BCBSM), which concluded he received substantial overpayments and provided investigative materials to police.
Michigan State Police Detective-Sergeant Lisa Gee‑Cram prepared affidavits and obtained search warrants for Sampson’s offices, residence, and related bank accounts; the financial warrants authorized seizure of "any and all accounts related" to Sampson/Argyle.
BCBSM employees accompanied law enforcement during the January 19, 2010 searches; they assisted in locating and reviewing patient files while officers supervised and approved seizures.
Bank employees, acting on a warrant served by Detective Rose, turned over funds from several accounts (including two in Fourth Street’s name on which Sampson was a signer).
State criminal proceedings followed; charges were later resolved by Argyle’s no‑contest plea and dismissal of other charges. Plaintiffs then sued under 42 U.S.C. § 1983 for Fourth Amendment violations (claims: improper financial warrants, wrongful seizure of Fourth Street accounts, unlawful civilian participation, and municipal failure to train).
The district court granted summary judgment to the officers on qualified immunity grounds; the Sixth Circuit AFFIRMED in full.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity of financial warrants / probable cause (Count I)	Warrant lacked probable cause to seize bank funds; officers knew or should have known it was deficient	Warrant was magistrate‑approved and affidavit showed extensive, sophisticated fraud making seizure of related accounts reasonable	Magistrate approval and affidavit details made officer reliance objectively reasonable; qualified immunity affirmed
Seizure of Fourth Street accounts not explicitly named (Count II)	Fourth Street accounts weren’t identified; seizure exceeded warrant scope	Warrant authorized seizure of accounts “related to” Sampson; bank determined accounts fit that description; officers relied on bank	Seizure did not show flagrant disregard for warrant limits; qualified immunity affirmed
Civilian (BCBSM) participation in executing warrants (Count V)	BCBSM used warrants to further its own interests and effectively conducted raids, not merely assisted officers	BCBSM personnel aided execution (document review, interviews) under officer supervision to facilitate the warrant	No factual dispute that BCBSM participation was in aid of the warrant; Bills/Wilson not triggered; qualified immunity affirmed
Municipal failure to train (Monell) (Count VI)	County/Township failed to train officers about supervising private parties, causing constitutional violations	Municipal liability requires underlying constitutional violation by officers	Because officers committed no constitutional violations, municipal failure‑to‑train claim fails

Key Cases Cited

Messerschmidt v. Millender, 132 S. Ct. 1235 (U.S. 2012) (magistrate‑issued warrant generally shields officers unless affidavit is so lacking that belief in probable cause is unreasonable)
Groh v. Ramirez, 540 U.S. 551 (U.S. 2004) (warrant with a glaring, obvious defect cannot justify officer reliance)
United States v. Leon, 468 U.S. 897 (U.S. 1984) (good‑faith exception to exclusionary rule and limits on warrant‑reliance defense)
Bray v. Planned Parenthood Columbia‑Willamette, Inc., 746 F.3d 229 (6th Cir. 2014) (civilian participation in searches and standard for clearly established law)
Bills v. Aseltine, 958 F.2d 697 (6th Cir. 1992) (private parties may not participate in executions for their own purposes unrelated to the warrant)
Wilson v. Layne, 526 U.S. 603 (U.S. 1999) (police may not bring media/third parties into a home during warrant execution when their presence is not in aid of the warrant)
Marcilis v. Twp. of Redford, 693 F.3d 589 (6th Cir. 2012) (search exceeds warrant where officers flagrantly disregard its limitations)