Maryann Godboldo v. County of Wayne
686 F. App'x 335
| 6th Cir. | 2017Background
- Godboldo and her daughter AG-H sue Wayne County and Mia Wenk under 42 U.S.C. § 1983 for an alleged Fourth Amendment unlawful seizure related to a state-custody order.
- Wenk sought dismissal and/or summary judgment asserting qualified immunity; district court denied parts of the motion and held Wenk had no immunity on the § 1983 seizure claim.
- The district court then ruled Wenk had absolute immunity for filing the petition to take AG-H into protective custody and dismissed most federal and state-law claims against Wenk, but left the seizure claim live.
- Plaintiffs’ state-court litigation established probable cause and the court order's validity; the Michigan courts ultimately determined there was probable cause and that the order was valid under state law and the Fourth Amendment.
- The panel applies collateral estoppel to preclude relitigation of probable cause and the order’s validity, and concludes Wenk is entitled to qualified immunity on the federal claims and governmental immunity on state-law claims, warranting reversal and remand.
- Wayne County and the other non-Wenk defendants were dismissed from the suit; only Wenk remains as a defendant on the federal claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wenk is entitled to qualified immunity for the Fourth Amendment seizure claim | Godboldo argues Fourth Amendment rights were violated and not clearly established | Wenk contends the district court correctly applied qualified immunity given state-court determinations | Yes; the court held Wenk entitled to qualified immunity for the Fourth Amendment claim |
| Whether collateral estoppel bars relitigation of probable cause and the custody order | Godboldo seeks to relitigate the Michigan determinations | Wenk seeks to give preclusive effect to Michigan state-court decisions | Yes; collateral estoppel applies to foreclose claims about probable cause and order validity |
| Whether state governmental immunity shields Wenk from state-law tort claims | Plaintiffs allege state-law torts based on Wenk’s conduct | Wenk is immune under Michigan governmental immunity for discretionary, good-faith acts | Yes; the district court’s denial of governmental immunity is reversed for Counts IV–V; Wenk is immune |
Key Cases Cited
- Kovacic v. Cuyahoga Cty. Dep't of Children & Family Servs., 724 F.3d 687 (6th Cir. 2013) (Fourth Amendment applicability to state actors; removal of child is a seizure if based on order and probable cause)
- Saucier v. Katz, 533 U.S. 194 (U.S. 2001) (establishes two-prong test for qualified immunity; alternative order permissible after Pearson)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (reaffirms that the two prongs may be addressed in any order)
- Heyne v. Metro. Nashville Pub. Sch., 655 F.3d 556 (6th Cir. 2011) (standard for evaluating a denial of qualified-immunity motion on a complaint)
- Chappell v. City of Cleveland, 585 F.3d 901 (6th Cir. 2009) (protects officials when their conduct does not clearly violate rights)
- Gilbert v. Ferry, 413 F.3d 578 (6th Cir. 2005) (collateral estoppel in Mich. state-law context (per curiam))