Randall Mills v. Weakley Barnard
869 F.3d 473
| 6th Cir. | 2017Background
- Mills was accused by C.M. in 1999 of sexual offenses; DNA evidence became central to the case.
- The initial indictment occurred before DNA results were analyzed, creating a probable-cause framework based on those allegations.
- DNA testing later conducted by SERI exonerated Mills, revealing two male contributors not including Mills.
- After a sequence of indictments and post-conviction developments, Mills obtained a new-trial grant and was later released.
- Tennessee appellate proceedings and a subsequent state-nolle prosequi left Mills’s case exposed to a federal civil action.
- In 2014 Mills filed a federal § 1981, § 1983, and § 1985 suit naming Jenkins, Barnard, Rhoton, and others; the district court dismissed several federal claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Malicious prosecution viability against Jenkins | Mills alleges Jenkins knowingly or recklessly fabricated or concealed exculpatory DNA evidence. | Probable cause existed due to indictment; actions were not knowingly false or malicious. | Complaint plausibly states a malicious-prosecution claim against Jenkins. |
| Fabrication of evidence claim viability | Jenkins fabricated or knowingly misrepresented DNA results to procure Mills’s conviction. | No clear factual basis that Jenkins acted knowingly or recklessly at this stage. | Fabrication-of-evidence claim plausibly stated. |
| Brady (withholding of exculpatory evidence) viability | Jenkins suppressed exculpatory DNA evidence mischaracterized as inconclusive, undermining Mills’s defense. | District court relied on the absence of Jenkins’s possession of certain material; Brady claim failed as pleaded. | Brady claim plausibly stated as to withholding/exculpatory evidence. |
Key Cases Cited
- Sykes v. Anderson, 625 F.3d 294 (6th Cir. 2010) (elements of Fourth Amendment malicious-prosecution claim; influence/participation in prosecution)
- Gregory v. City of Louisville, 444 F.3d 725 (6th Cir. 2006) (fabrication evidence and suppression of exculpatory evidence; separate analysis of claims)
- Webb v. United States, 789 F.3d 647 (6th Cir. 2015) (grand-jury indictment generally conclusive of probable cause, with exception for false fabrication)
- King v. Harwood, 852 F.3d 568 (6th Cir. 2017) (pre-indictment, non-testimonial acts can rebut probable cause if knowingly or recklessly false)
- Moldowan v. City of Warren, 578 F.3d 351 (6th Cir. 2009) (Brady duty extends to police and forensic experts; suppression of evidence analyzed)