Gavitt v. Born, No. 15-2434 (6th Cir. 2016)
Annotate this CaseA house fire took the lives of Gavitt’s wife and two daughters. Gavitt, convicted of arson and felony murder, was sentenced to life in prison in 1986. In 2012, the state court granted Gavitt’s unopposed motion for relief. Advancements in fire science research and investigation methods impugned some of the evidence on which Gavitt’s convictions were based. The judgment was vacated and Gavitt was released. Gavitt brought a civil rights action, claiming that multiple defendants violated his due process rights by intentionally misrepresenting evidence, failing to disclose exculpatory evidence, and conspiring to deprive him of his rights. The district court dismissed, except with respect the Estate of DeVries, a Michigan forensic laboratory technician who testified at Gavitt’s trial. The Sixth Circuit affirmed. The record is not so clear as to permit a ruling that the Estate’s evidence-sufficiency appeal presents a purely legal issue. While the likelihood that discovery will reveal evidence of intentional or reckless wrongdoing may be minimal, it is not inconceivable. While Gavitt may have been “wronged,” he did not sufficiently allege facts to support his claims that other defendants acted with such culpable states of mind as to warrant relief under 42 U.S.C. 1983. Due process guarantees a right to a fair trial, not perfection. Using the methods of the 1980s during the 1980s did not violate the Constitution; the defendants are entitled to qualified immunity.
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