Watkins v. Healy, No. 20-1074 (6th Cir. 2021)
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In 1975, schoolteacher and drug dealer Ingram was robbed and shot dead in her Detroit home. Watkins’s 20-year-old high school classmate, Herndon, testified that he and Watkins robbed and murdered Ingram together. Detroit Evidence Technician Badaczewski testified that a hair found on Ingram’s clothing matched Watkins's hair sample. After Watkins’s conviction, Herndon repeatedly recanted. In sworn affidavits, letters, and testimony, Herndon attested that Wayne County Prosecutor Healy and Detective Schwartz threatened to charge him with Ingram’s murder and another murder if Herndon did not implicate Watkins and testify at Watkins’s trial. Watkins’s efforts to overturn his conviction had no success for four decades.
In 2017, Watkins presented new evidence that Badaczewski’s hair analysis methods were seriously flawed. The Michigan court dismissed the case against Watkins without prejudice. Months later, Watkins filed a 42 U.S.C. 1983 suit against Healy, Schwartz's estate, Badaczewski, and Detroit.
The district court denied Healy’s motion to dismiss. The Sixth Circuit found that it lacked jurisdiction to consider most of Healy’s arguments but held that Healy is not entitled to absolute immunity and that Healy forfeited the issue of qualified immunity at this stage. Even considering Healy’s equitable contentions that it would not be “fair” to hold him to today’s standards, the 1975-76 standards of prosecutorial immunity were the same: a prosecutor engaged in certain investigative activities enjoys, not the absolute immunity associated with the judicial process, but only a good-faith defense comparable to the policeman’s.”
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