Chambers v. Sanders, No. 22-1446 (6th Cir. 2023)
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In 1987, a Michigan jury convicted Burton of first-degree murder and a firearm charge. He was sentenced to life in prison without the possibility of parole. In 2019, Burton was released from prison and his conviction was vacated on the prosecutor’s motion after key witnesses recanted and details of witness manipulation and intimidation were revealed. Detective Sanders’s investigative tactics allegedly included threats and physical violence against witnesses, including minors. In 2020,
Burton filed claims under 42 U.S.C. 1983 and 1988 against Sanders and Detroit for Brady violations, malicious prosecution, and fabrication of evidence. The district court dismissed Burton’s claims as barred by Detroit’s Chapter 9 bankruptcy which occurred after Burton’s claims arose. Burton’s claims against Sanders remain pending. Burton’s sons then filed suit against Sanders and the city, alleging that the wrongful conviction and incarceration of their father throughout their childhood and into adulthood violated their constitutional right to family integrity. The district court dismissed, finding no cognizable due process right for “interference with family integrity” when a party is indirectly harmed by a constitutional tort against a family member. The Sixth Circuit affirmed; the plaintiffs have not alleged that the defendants acted with a culpable state of mind, directed toward them or their family unit.
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