Sykes v. Anderson
2010 U.S. App. LEXIS 23204
| 6th Cir. | 2010Background
- In 2002, Sykes, Urquhart, and Holmes were robbed at a Sprint store; two armed men conducted the robbery and left with about $27,000.
- Urquhart, three months pregnant, opened the safe under duress; surveillance video exists but has dead spots; two officers investigated.
- Sgt. Anderson led the investigation after replacing Sgt. Nichols; he relied on misrepresentations and omissions in warrant materials and did not disclose casino records with a disclaimer.
- A deputy prosecutor obtained warrants for false arrest and larceny by conversion; Sykes and Urquhart were arrested in 2002 and later tried; both were convicted in Michigan courts which were later reversed.
- The federal §1983 action alleged false imprisonment, malicious prosecution, and due-process violations; the district court denied some city claims and the jury awarded damages to Plaintiffs.
- The Sixth Circuit affirmed liability on false arrest, malicious prosecution, and Brady-related due-process claims, remanded for remittitur explanation, and held cross-appeals in abeyance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Qualified immunity waiver | Sykes argues Anderson/Nichols lacked qualified immunity; defense failed to raise pre-verdict issues. | Defendants argue they raised immunity; but the court found waiver due to lack of Rule 50(a) pre-verdict framing. | Waived liability defense under Rule 50(a)/(b). |
| Probable cause and false arrest | Plaintiffs lacked probable cause; officers misrepresented evidence to obtain warrants. | Argued probable cause existed based on surveillance and statements. | District court correctly denied JMOL on false arrest; jury could find lack of probable cause. |
| Malicious prosecution elements and causation | Officers influenced or participated in decision to prosecute via misstatements. | Prosecutors decide; officers not liable. | Plaintiffs shown sufficient causation and influence; liability affirmed for malicious prosecution. |
| Brady violation and due process | Disclosed casino records impeachment evidence; failure prejudiced trial. | No Brady violation; evidence not favorable/prejudicial or available elsewhere. | Brady-based due-process claim sustained; evidence was favorable and prejudicial. |
| Remittitur and damages | Damages appropriate; no error in jury award. | Remittitur needed due to excessive damages; district court offered no reasoning. | Remand for district court to provide reasons for remittitur denial. |
Key Cases Cited
- Ford v. County of Grand Traverse, 535 F.3d 483 (6th Cir.2008) (pre-verdict Rule 50(a) notice requirements; waiver if not raised)
- Malley v. Briggs, 475 U.S. 335 (1986) (causal chain in §1983; officer liable for consequences of misdeed)
- Fox v. DeSoto, 489 F.3d 227 (6th Cir.2007) (elements for malicious-prosecution claim under §1983)
- Voyticky v. Village of Timberlake, 412 F.3d 669 (6th Cir.2005) (probable cause and false arrest standard; procedural nuances)
- Gregory v. City of Louisville, 444 F.3d 725 (6th Cir.2006) (testimony at probable-cause hearings; materiality of misstatements)
- Moldowan v. City of Warren, 578 F.3d 351 (6th Cir.2009) (Brady obligations applicable to police; derivative liability)
- Hinchman v. Moore, 312 F.3d 198 (6th Cir.2002) (probable cause and totality of circumstances)
- Frantz v. Village of Bradford, 245 F.3d 869 (6th Cir.2001) (Albright preclusion of state-law elements in §1983)