Nathaniel Hatchett v. City of Detroit
495 F. App'x 567
6th Cir.2012Background
- Hatchett was convicted in 1998 of carjacking, armed robbery, kidnapping, and first-degree criminal sexual conduct.
- A DNA report later surfaced showing semen did not originate from Hatchett or the husband; Hatchett was released.
- Hatchett sued under §1983 alleging due-process violations by Detroit and Sterling Heights officials and others.
- Key dispute: whether the husband’s exculpatory DNA results were withheld and whether Hatchett’s confession was coerced.
- Hatchett’s Walker hearing found his confession voluntary; the district court ruled collateral estoppel barred later challenges.
- The district court granted summary judgment to all defendants; Hatchett appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Collateral estoppel bars voluntariness claim | Hatchett contends Walker finding is not estopped by final judgment. | Defendants rely on Michigan law allowing preclusion of voluntariness determinations. | Collateral estoppel applies; Walker voluntariness final. |
| Kaiser immunity for Brady claim | Hatchett alleges Kaiser withheld/destroyed exculpatory DNA results. | Prosecutor immunity extends to disclosure duties; no destruction claim shown. | Kaiser immune from Brady claim. |
| Officer Van Sice Brady disclosure duty | Van Sice failed to disclose exculpatory DNA results to Kaiser. | Results were transmitted to Kaiser; no per se Brady violation by Van Sice. | No Brady violation; duty was satisfied by transmission. |
| Supervisory liability/training nexus to Brady | County and Marlinga failed to train prosecutors regarding Brady. | Under Connick, no pattern or policy shown; supervisory liability requires more. | Claims fail; no actionable training or policy violation shown. |
| Discovery ruling not abuse of discretion | Additional discovery needed to probe training and policies. | Discovery denial appropriate; Connick controls outcome. | No abuse; discovery ruling affirmed. |
Key Cases Cited
- People v. Walker, 374 Mich. 331 (1965) (Walker hearing governs voluntariness; admissibility focus)
- Moldowan v. City of Warren, 578 F.3d 351 (6th Cir. 2009) (Brady duties extend to exculpatory evidence to prosecutor)
- Connick v. Thompson, 131 S. Ct. 1350 (2011) (recurrent Brady violations not automatic due to training)
- Koubriti v. Convertino, 593 F.3d 459 (6th Cir. 2010) (prosecutor immunity extends to core judicial-process duties)
- Van de Kamp v. Goldstein, 555 U.S. 335 (2009) (supervisory liability for prosecutors and training constraints)
- Buck v. Thomas M. Cooley Law School, 597 F.3d 812 (6th Cir. 2010) (same-state final judgments give collateral-estoppel effect)
- Manning v. Manning, N/A () (not cited for official reporter; omitted)
- Storey v. Meijer, Inc., 429 N.W.2d 169 (Mich. 1988) (Michigan collateral estoppel framework)
- People v. Manning, N/A () (not official reporter; omitted)