James Saltmarshall v. Prime Healthcare Servs.

CourtCourt of Appeals for the Sixth Circuit
DecidedOctober 13, 2020
Docket19-1898
StatusUnpublished

This text of James Saltmarshall v. Prime Healthcare Servs. (James Saltmarshall v. Prime Healthcare Servs.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Saltmarshall v. Prime Healthcare Servs., (6th Cir. 2020).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 20a0581n.06

No. 19-1898

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

JAMES LEE SALTMARSHALL, ) FILED Oct 13, 2020 ) Plaintiff-Appellant, DEBORAH S. HUNT, Clerk ) ) v. ) PRIME HEALTHCARE SERVICES-GARDEN ) ) ON APPEAL FROM THE CITY LLC, ) UNITED STATES DISTRICT Defendant, ) COURT FOR THE EASTERN ) DISTRICT OF MICHIGAN ) JEFFREY SMITH and JONATHAN MUNSON, ) Defendants-Appellees. ) )

BEFORE: DAUGHTREY, DONALD, and READLER, Circuit Judges.

CHAD A. READLER, Circuit Judge. James Saltmarshall fell asleep with his eight-

month-old daughter, Janiyah, in his arms. When he woke up, Janiyah was not breathing.

Paramedics rushed Janiyah to the hospital, but, tragically, her life could not be saved.

In addition to losing a daughter, Saltmarshall faced even further tragedy. Rather than being

allowed to be with his ailing daughter, he was arrested after a doctor noticed what she believed to

be signs of sexual trauma on Janiyah’s body. Saltmarshall spent the next week in jail, only hearing

about his daughter’s death at his arraignment. When Janiyah’s autopsy later revealed no signs of

sexual trauma or abuse, the charges against Saltmarshall were dropped. Case No. 19-1898, Saltmarshall v. Prime Healthcare, et al.

Too hollow a vindication, Saltmarshall filed a 42 U.S.C. § 1983 suit against, among others,

the officers who arrested and investigated the allegations against him. The district court granted

summary judgment in favor of defendants and dismissed the suit. Because both the decision to

arrest Saltmarshall and to prosecute him were supported by probable cause based on the officers’

temporal knowledge, District of Columbia v. Wesby, 138 S. Ct. 577, 586 (2018), we must affirm.

BACKGROUND

Every parent has had a day start like James Saltmarshall’s. His eight-month-old daughter,

Janiyah, was crying from an upset stomach and constipation. She needed to take a nap, but

Saltmarshall had left her Pack n’ Play at his father’s house. And Saltmarshall’s car would not

start. Resigned, Saltmarshall changed Janiyah’s diaper, made her bottle, and sat down on the bed

to feed her. After she ate, Janiyah fell asleep. Saltmarshall turned on a movie, at which point he

too fell asleep, albeit by accident, with Janiyah in his arms.

And every parent has prayed to never have a day end like Saltmarshall’s. When he woke

up, he noticed that Janiyah did not look quite right. Her head was limp, and she wasn’t breathing.

Saltmarshall frantically called 911. An ambulance and Inkster (Michigan) police officers were

immediately dispatched. Lieutenant Jeffery Smith was one of the officers to respond. Saltmarshall

explained to Smith what happened, and Smith surveyed the location. Janiyah was rushed to the

hospital, with Saltmarshall and the officers shortly behind.

Saltmarshall’s Arrest. Janiyah was in critical condition when she arrived at the ER.

Saltmarshall explained to Dr. Shawna Wright, the attending ER physician, that he had been holding

Janiyah, placed her on the bed, and then noticed she was not breathing. He did not explain to

Wright that he had been sleeping with Janiyah. While examining Janiyah, Wright noticed signs

2 Case No. 19-1898, Saltmarshall v. Prime Healthcare, et al.

of trauma that seemed inconsistent with Saltmarshall’s story, including a large rectal tear that was

bleeding.

After evaluating Janiyah’s condition, Wright expressed to Smith her concern for Janiyah’s

wellbeing. Wright told Smith that “Janiyah had injuries to her anus as well as a relatively large

amount of rectal bleeding which could not be explained by the description of the incident given by

[Saltmarshall].” Such an injury, Wright explained, may result from something being inserted into

the rectum, telltale signs of child abuse. Wright in turn reported her suspicions of known or

suspected child abuse to Children’s Protective Services. And Smith, for his part, arrested

Saltmarshall for suspected sexual assault of a minor. See MCL § 750.520b(1)(a).

Investigation. As more doctors examined Janiyah, the more severe the charges became.

One doctor texted an update to one of the officers working Janiyah’s case: “[B]aby has skull

fractures, brain swelling on CT (likely will meet brain death criteria), lung bruising, anterior anal

laceration. We have some other studies pending. This is non-accidental trauma. The perpetrator

murdered this child.” Another said that Janiyah had head trauma consistent with shaken baby

syndrome, although the doctor did not see skull fractures or external head trauma.

Smith assigned Detective Jonathan Munson to investigate Saltmarshall’s case. Munson

spoke with Janiyah’s doctors and reviewed messages they sent to the officers. He also interviewed

Janiyah’s mother, who told Munson that she did not believe Saltmarshall would hurt Janiyah. All

the while, Saltmarshall sat in a jail cell, pleading with officers to believe that he did not assault his

daughter. He spoke twice with Munson, each time tearfully explaining what happened. “My

daughter was fine. We went to sleep. I wake up and she is dead because I suffocated her too much

in the middle of my sleep;” “I held her too close. I just didn’t want her to fall off the bed, man.”

3 Case No. 19-1898, Saltmarshall v. Prime Healthcare, et al.

Munson asked Saltmarshall about Janiyah’s other reported injuries—possible skull

fracture, likely head trauma, and a seemingly large rectal tear. At first, Saltmarshall responded

“[w]hat are the injuries? I’m lost.” When Munson pushed Saltmarshall, he tried to explain possible

reasons for two of the injuries. As he realized Janiyah wasn’t breathing, Saltmarshall thought he

might have shaken her to try and wake her. And when he was performing CPR, Saltmarshall was

so hysterical that Janiyah slipped out of his hands, possibly hitting her head. Saltmarshall

consistently denied any involvement in Janiyah’s rectal injuries.

Munson detailed all of his findings in a warrant request. He did not make a

recommendation in favor of or against prosecuting Saltmarshall. Munson submitted his request

for a warrant to the Wayne County Prosecuting Attorney’s Office. An assistant prosecuting

attorney reviewed Munson’s request, Janiyah’s medical records, and Janiyah’s Sexual Assault

Forensic Examination (SAFE) report and decided to charge Saltmarshall with (1) felony murder,

(2) first-degree criminal sexual assault, and (3) first-degree child abuse. At an arraignment hearing

the following day, Saltmarshall learned the tragic news that Janiyah had died the day before. Based

upon Smith’s testimony and supporting evidence, a judge found sufficient probable cause to issue

an arrest warrant.

Saltmarshall’s Release. Later that day, medical examiners conducted an autopsy of

Janiyah’s body. The examiner expected to see trauma consistent with the examining doctors’

reports—a large rectal tear, brain injuries from being shaken, and a possible skull fracture. But

the autopsy indicated otherwise. The seemingly large rectal tear turned out to be a minute fissure,

likely caused by Janiyah’s constipation. The alleged skull fracture was just a small laceration.

And Janiyah’s body did not show signs of shaken baby syndrome. The autopsy report concluded

4 Case No. 19-1898, Saltmarshall v. Prime Healthcare, et al.

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