Washington v. Wayne County Prosecutor

CourtDistrict Court, E.D. Michigan
DecidedJune 24, 2025
Docket2:25-cv-11491
StatusUnknown

This text of Washington v. Wayne County Prosecutor (Washington v. Wayne County Prosecutor) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Washington v. Wayne County Prosecutor, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

SHERMAN LANCE WASHINGTON, Civil Action No. 25-11491 Plaintiff, David M. Lawson v. United States District Judge

WAYNE COUNTY PROSECUTOR, David R. Grand and GREGORY HILL, United States Magistrate Judge

Defendants. __________________________________/

REPORT AND RECOMMENDATION TO DISMISS PLAINTIFF’S COMPLAINT (ECF No. 1) UNDER 28 U.S.C. § 1915(e) I. RECOMMENDATION Plaintiff Sherman Washington (“Washington”), an incarcerated person, brings this pro se civil rights action against defendants “Wayne County Prosecutor” and Gregory Hill. (ECF No. 1). Washington has been granted permission to proceed in forma pauperis in this case.1 (ECF No. 5). The Court now having assessed the sufficiency of the complaint pursuant to 28 U.S.C. § 1915(e), IT IS RECOMMENDED that Washington’s complaint be DISMISSED. II. REPORT A. Background On May 13, 2025, Washington filed his complaint in this case, alleging violations of the Fourth and Fourteenth Amendments by the “Wayne County Prosecutor” and

1 This case has been referred to the undersigned for all pretrial purposes. (ECF No. 6). Gregory Hill, a police officer with the Detroit Police Department. (ECF No. 1). Washington’s instant case arises out of his October 1988 state court conviction on a theft charge. Washington alleges that, in September 1987, he and another individual – identified

only as “Lewis” – were arrested by Officer Hill “without probable cause.” (Id., PageID.5). Washington alleges that both he and Lewis were accused of breaking into a middle school, taken to the local precinct, and “booked and released the next day.” (Id.). Washington further alleges that neither he nor Lewis was told to appear in court “because it was assumed [they] all knew the boys were falsely arrested.” (Id.).

According to Washington, he had signed up for the United States Army Reserve in May 1987, and after his arrest in September 1987, he proceeded to attend Basic and Advanced Individual Training in Texas. (Id.). When he returned to Detroit, he was arrested and prosecuted for breaking into the middle school and stealing property. (Id.). Washington further alleges that, during the preliminary examination (which was held on

August 9, 1988), Officer Hill testified that “two people” were seen leaving the middle school “with boxes in hand,” were chased, and were caught by Officer Hill and others. (Id.). Washington was found guilty in October 1988; however, “Lewis” was never prosecuted for the crime, allegedly because his uncle was “friends with the police.” (Id., PageID.6).

Now, some 37 years later, Washington filed his instant complaint claiming that because Officer Hill and the Wayne County Prosecutor only prosecuted one suspect for a crime that allegedly had been committed by two people, there was “an inequality in the law” that amounted to a “malicious prosecution.” (Id., PageID.7). Washington asks that the state court criminal case be “dismissed from [his] record,” which is important to him now because “it is factored into [his] current sentence” for a different crime.2 (Id.). Washington also alleges that his 1988 conviction “messed up his whole life” and he seeks

damages in excess of $3.5 million. (Id., PageID.5, 7). B. Applicable Legal Standards Under the Prison Litigation Reform Act of 1996 (“PLRA”), the Court shall sua sponte dismiss an in forma pauperis complaint “at any time” if it determines that the action is frivolous or malicious, fails to state a claim upon which relief can be granted, or seeks

monetary relief against a defendant who is immune from such relief. See 42 U.S.C. §1997e(c); 28 U.S.C. §1915(e)(2)(B). In performing this review, the Court must construe the pro se plaintiff’s complaint liberally and hold it to a less stringent standard than one drafted by an attorney. See Spotts v. United States, 429 F.3d 248, 250 (6th Cir. 2005). Even applying this liberal standard, however, Washington’s complaint fails to state a claim

upon which relief may be granted. C. Analysis To state a civil rights claim under 42 U.S.C. § 1983, a plaintiff must allege that: (1) he was deprived of a right, privilege, or immunity secured by the federal Constitution or laws of the United States; and (2) the deprivation was caused by a person acting under

color of state law. See Harris v. Circleville, 583 F.3d 356, 364 (6th Cir. 2009).

2 According to publicly available records, Washington was convicted of first-degree home invasion in 2012. See https://mdocweb.state.mi.us/OTIS2/otis2profile.aspx?mdocNumber=207519 (last accessed June 9, 2025). As set forth above, Washington first alleges that he was arrested without probable cause, resulting in his malicious prosecution, in violation of the Fourth Amendment. Specifically, Washington asserts:

Washington (plaintiff) and Lewis were standing on Pasquale Koyton’s porch. Pasquale is Lewis’s uncle. Officer Gregory Hill arrested them, single handedly, without probable cause. Hill took the boys to Farewell Middle School, accused them of breaking in, then took them to the local precinct. Where they were booked and released the next day. They were not told to show up for court because it was assumed we all knew the boys were falsely arrested. This was September 1987. (ECF No. 1, PageID.5). Washington also asserts that his selective prosecution violated the Equal Protection Clause of the Fourteenth Amendment: Because Washington was getting his life together and Lewis’s uncle was friends with the police, we believe Washington was maliciously prosecuted. As the charges were fabricated, Washington should’ve not been prosecuted. Just like Lewis wasn’t. To pursue one and not both is a violation of equal protection under the law. (Id., PageID.6). For the reasons explained below, both claims fail to state a claim upon which relief can be granted and should be dismissed. 1. Malicious Prosecution Washington’s Fourth Amendment claim – which is focused on the absence of “probable cause” for his arrest and his subsequent “malicious prosecution” – fails as a matter of law. Incarcerated persons typically may not use § 1983 to challenge the validity of their imprisonment, only its conditions. See Heck v. Humphrey, 512 U.S. 477, 486-87 (1994) (“[I]n order to recover damages for allegedly unconstitutional conviction or imprisonment, or for other harm caused by actions whose unlawfulness would render a conviction or sentence invalid, a § 1983 plaintiff must prove that the conviction or sentence has been reversed on direct appeal, expunged by executive order, declared invalid by a state tribunal authorized to make such determination, or called into question by a federal

court’s issuance of a writ of habeas corpus[.]”) (footnote omitted).

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Washington v. Wayne County Prosecutor, Counsel Stack Legal Research, https://law.counselstack.com/opinion/washington-v-wayne-county-prosecutor-mied-2025.