Latest Case: Seales v. City of Detroit (Civil Rights)

Disaster Relief to States and Cities Is Both Right and Good: Part 1 of 2

NEIL H. BUCHANAN

In this first of a series of columns about federal relief to state and local governments, UF Levin College of Law professor and economist Neil H. Buchanan provides the economic background to explain how unprecedented these times are and argues that supporting cities and states is essential to surviving this crisis.

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Seales v. City of Detroit

Docket: 19-1555

Opinion Date: May 13, 2020

Judge: Jeffrey S. Sutton

Areas of Law: Civil Rights, Constitutional Law, Criminal Law

Sergeant Faith of the Detroit Fugitive Apprehension Team, tasked with arresting “Marvin Seales a/k/a Roderick Siner,” met Officer Zberkot at a food processing plant. A manager led them to Seales. Seales protested, “You got the wrong guy.” Faith handcuffed Seales and drove him to the precinct. Zberkot drafted a report. Other officers handled the rest of the process. Seales repeatedly told Zberkot that he was innocent and asked Zberkot to check his identification. Seales spent two nights in the precinct. At his arraignment, the judge called People "versus Roderick Siner.” Asked for his name, Seales said “Marvin Seales.” He later thought “I better say, Roderick Siner, I understand these charges” to “get past that point.” Seales spent two weeks in the Wayne County Jail. Seales filed a grievance but signed a medical intake form “Siner” because he wanted to make sure he could get medical attention if needed. No one investigated his claims. At his preliminary examination, the victim stated that Seales was not the man who shot at him. The case was dismissed. Seales sued under 42 U.S.C. 1983. The district court rejected claims against Detroit and Wayne County. Zberkot unsuccessfully raised several immunities. The Sixth Circuit rejected Seales’ unlawful arrest claim as a matter of law due to the similarities between Seales and the true suspect but allowed the unlawful detention claim to proceed. A jury awarded Seales $3.5 million. The Sixth Circuit reversed, noting its prior decision that there was probable cause to arrest Seales and that Zberkot handled the case for fewer than three hours.