Hart v. Hillsdale County, No. 18-1307 (6th Cir. 2020)
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In 2011, Michigan narrowed the crimes covered by the Sex Offender Registration Act (SORA) making Hart, who had been a juvenile offender, no longer a “sex offender.” Local officials required him to continue registering as one. In 2013, Hart registered an incorrect address and, in January 2014, he failed to update his address. The defendants arrested Hart each time, using warrant requests incorrectly representing that he was required to register under SORA. The first time, Hart spent the night in jail; the second time, he served 19 months in prison. When prison officials realized the mistake, they released Hart and his convictions were vacated.
Hart sued (42 U.S.C. 1983) for false arrest, malicious prosecution, and defamation. The court denied motions to dismiss by employees of the city police and county sheriff’s departments, citing qualified immunity. The Sixth Circuit affirmed with respect to false arrest, malicious prosecution, and Monell claims, as well as the defamation claim against registration officials; reversed regarding the defamation claim against three officers; and remanded. Taking the facts in the light most favorable to Hart, a reasonable officer could not believe that Hart was subject to SORA’s requirements based solely on his inclusion in the database. Without additional evidence, it is impossible to determine individual culpability.
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