Peterson v. Heymes, No. 17-2270 (6th Cir. 2019)
Annotate this CaseIn 1996, Montgomery was sexually assaulted and murdered in her Kalkaska, Michigan home. Months later, 22-year-old Peterson was in jail on an unrelated charge. Another inmate informed officers that Peterson had made an incriminating statement about the Montgomery crime. Peterson claims that he suffered from brain damage, mental illness, and severe depression, was on suicide watch, and that the defendants knew of Peterson’s disabilities. Peterson initially denied involvement, but after nine interrogations and several polygraph examinations, Peterson confessed. A week later, DNA results showed that Peterson’s DNA was not a match for a vaginal semen sample. Peterson was convicted. In 2013, Peterson’s attorneys obtained new DNA test results that excluded Peterson as a contributor to a previously-inconclusive sample from the victim’s shirt. Peterson’s conviction was vacated in 2014. Peterson filed suit, 42 U.S.C. 1983. The officers each raised qualified immunity, arguing Peterson was collaterally estopped from relitigating the voluntariness of his confession, which the Michigan trial court had determined was admissible. The district court rejected that argument and denied the defendants qualified immunity, absolute witness immunity, and governmental immunity. The Sixth Circuit affirmed with respect to two officers but reversed with respect to one officer, who was not alleged to have participated in the interrogations. The court reversed the decision to deny governmental immunity to the county. The state court ruling regarding the confession was vacated with the conviction.
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