Richard Steiger v. Robert Hahn
16-2531
| 6th Cir. | Jan 3, 2018Background
- In 2011 Steiger’s ex-wife reported suspected "doctor shopping." Officers obtained his MAPS report showing ~6,400 Schedule II pills over two years from two physicians.
- SANE investigators consulted the Michigan AG’s Office and obtained an expert medical review (Dr. Kirk Mills) who opined the MAPS pattern was consistent with misuse/diversion.
- Investigators interviewed Steiger and his prescribers (Drs. Kiel and Coombs); physicians gave differing recollections about whether Steiger disclosed other prescriptions. Some records indicated he had disclosed them.
- AAG Richard Cunningham reviewed the file, concluded there was probable cause for fraudulently obtaining controlled substances, and authorized an arrest warrant; Steiger surrendered and was charged.
- A state court held a preliminary exam and dismissed the charge for insufficient evidence of fraud; Steiger sued officers under 42 U.S.C. § 1983 (Fourth Amendment seizure/ malicious prosecution, First Amendment retaliation, due process) and asserted a state-law gross negligence claim.
- District court granted summary judgment for defendants on federal claims (qualified immunity) and dismissed the state claim without prejudice; Sixth Circuit majority affirmed, Judge Clay dissented.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause / Fourth Amendment (false arrest / malicious prosecution) | Steiger: officers lacked probable cause because physicians’ records and testimony supported legitimate chronic-pain treatment and showed disclosure of other prescriptions. | Officers: MAPS data, physician interviews, and AG/expert review provided objectively reasonable basis for probable cause; they relied on AG determination. | Affirmed: No violation; qualified immunity protects officers because reliance on AG/expert and absence of evidence of deliberate/reckless falsehoods made actions reasonable. |
| Qualified immunity | Steiger: officers were reckless/knowingly false in omissions and influenced charging despite weak evidence. | Officers: their conduct was objectively reasonable; all but plainly incompetent actors are shielded; prosecutor independently approved charges. | Affirmed: Officers entitled to qualified immunity; not plainly incompetent or knowingly violating law. |
| First Amendment retaliation | Steiger: prior criticism motivated retaliatory prosecution. | Officers: AG independently determined probable cause; under Hartman, charges would have been brought absent retaliatory motive. | Affirmed: Claim fails because prosecutor’s independent charging decision defeats alleged retaliatory motive. |
| Due process & supplemental jurisdiction | Steiger: reputational and familial harms from wrongful charge; district court should retain state claim. | Officers: no conscience-shocking conduct; federal claims fail so dismissal of state claim without prejudice was proper discretionary choice. | Affirmed: No substantive due process violation; district court permissibly declined supplemental jurisdiction over state claim. |
Key Cases Cited
- Santiago v. Ringle, 734 F.3d 585 (6th Cir. 2013) (qualified immunity/summary-judgment review standard)
- Tolan v. Cotton, 134 S. Ct. 1861 (2014) (summary judgment must view facts in light most favorable to nonmoving party)
- Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity two-step framework)
- Ashcroft v. al-Kidd, 563 U.S. 731 (2011) (clearly established law standard for qualified immunity)
- Malley v. Briggs, 475 U.S. 335 (1986) (officer seeking warrant entitled to immunity only if objectively reasonable belief in probable cause)
- Newman v. Twp. of Hamburg, 773 F.3d 769 (6th Cir. 2014) (officer liability where deliberate or reckless falsehoods produce arrest without probable cause)
- Ahlers v. Schebil, 188 F.3d 365 (6th Cir. 1999) (officer not liable where no reckless disregard for truth in warrant process)
- Hartman v. Moore, 547 U.S. 250 (2006) (retaliatory-prosecution claim requires proof that prosecution would not have occurred but for retaliatory motive)
- Fridley v. Horrighs, 291 F.3d 867 (6th Cir. 2002) (probable cause generally a jury question unless only one reasonable determination)
- Yancey v. Carroll Cty., 876 F.2d 1238 (6th Cir. 1989) (officer cannot rely on magistrate if he knowingly makes false statements/omissions)