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Watkins v. Healy

United States District Court, E.D. Michigan, Southern Division

March 26, 2018

ROBERT H. HEALY, et al., Defendants.



         In 1976, Plaintiff Ledura Watkins was convicted of murder and sentenced to life in prison. In this action, Watkins asserts that Defendants Robert H. Healy, Neil Schwartz, [1] and Ronald Badaczewski violated his constitutional rights when they suppressed favorable evidence, fabricated evidence, maliciously prosecuted him, and conspired against him during the murder investigation and trial. (See Compl., ECF #1.) Watkins also maintains that Defendant the City of Detroit is liable for Defendants Schwartz and Badaczewski's constitutional violations because the City had a custom or policy authorizing those actions and/or because it failed to adequately train Defendants Schwartz and Badaczewski. (See id.) Defendant Healy has moved the Court to abstain from hearing and to stay this action pending the resolution of a state court action in which Watkins seeks compensation under a Michigan statute for wrongful imprisonment. (See Mot. to Abstain, ECF #8.) The other Defendants have concurred in the relief sought in Healy's motion. (See ECF #10.) For the reasons stated below, the Court DENIES the motion and will not abstain or stay this action.[2]



         On September 6, 1975, a Detroit school teacher named Yvette Ingram was found shot to death in her home. (See Compl. at ¶12, ECF #1 at Pg. ID 4.) Healy, then an Assistant Prosecuting Attorney employed by the Wayne County Prosecutor's Office, and Schwartz, then a Sergeant employed by the Detroit Police Department (the “DPD”), investigated the murder of Ingram. (See Id. at ¶¶ 5, 7, 18, Pg. ID 3, 4, 6.) Following the investigation, police arrested Watkins, and the Wayne County Prosecutor charged Watkins with murdering Ingram. (See Id. at ¶¶ 43-44, 51, Pg. ID 11-13.)

         Watkins was tried in Michigan's Recorder's Court. (See Id. at ¶¶ 51, 81, Pg. ID 12-13, 19.) At trial, the prosecution relied on two primary pieces of evidence: (1) testimony by an acquaintance of Watkins that he saw Watkins shoot Ingram and (2) expert testimony from Badaczewski, then an evidence technician with the DPD, that a hair found on Ingram matched Watkins' hair. (See Id. at ¶¶ 65-70, 77, Pg. ID 15-17.)

         On March 16, 1976, a jury convicted Watkins of first degree murder. (See Id. at ¶81, Pg. ID 19.) On April 15, 1976, the state trial court sentenced Watkins to a term of life imprisonment without the possibility of parole. (See id.)


         In 2017, Watkins filed a motion for relief from judgment in state court. (See ECF #8-7.) In that motion, Watkins argued that the state court should vacate his conviction because, among other reasons, (1) the witness who testified that he saw Watkins shoot Ingram recanted that testimony and (2) Badaczewski's testimony was unreliable, flawed, and failed to comport with the Federal Bureau of Investigation's revised standards for hair comparisons. (See id.) The Wayne County Prosecutor's Office agreed that Watkins' motion for relief from judgment should be granted. The prosecutor stipulated that Badaczewski's hair analysis was unreliable and that a retrial would probably result in Watkins' release. (See ECF #8-8.) On June 15, 2017, the state court entered a stipulated order granting Watkins' motion for relief from judgment and dismissing the case without prejudice. (See id.)


         On July 25, 2017, Watkins filed a lawsuit against the State of Michigan in the Michigan Court of Claims under Michigan's Wrongful Imprisonment Compensation Act (the “WICA”), Mich. Comp. Laws § 691.1751 et seq. (the “Court of Claims Action”). (See Ct. of Claims Compl., ECF #8-9.) The Michigan Legislature enacted the WICA to compensate formerly convicted persons who could show that new evidence established their innocence. See Mich. Comp. Laws § 691.1755(1) (requiring that a plaintiff prove as one element of a WICA claim that “[n]ew evidence demonstrates that the plaintiff did not perpetrate the crime and was not an accomplice or accessory to the acts that were the basis of the conviction . . . .”). The WICA sets compensation for a successful plaintiff at $50, 000 for each year imprisoned. See Id. The Michigan Court of Claims has exclusive jurisdiction over claims under the WICA. See Mich. Comp. Laws § 691.1753.

         Watkins alleges in the Court of Claims Action that new evidence, including the eye-witness's recantation of his testimony and the unreliability of Badaczewski's analysis and testimony, establishes his innocence. Thus, Watkins contends, he is entitled to compensation under the WICA. (See Ct. of Claims Compl., ECF #8-9.)

         Discovery has begun in the Court of Claims Action. Among other things, Watkins has taken the depositions of Healy and Badaczewski in that case.


         On December 6, 2017, Watkins filed this action against Healy, Schwartz, Badaczewski, and the City of Detroit. (See Compl., ECF #1.) In Count I of the Complaint, Watkins asserts the following constitutional violations under 42 U.S.C. § 1983 against the Defendants:

1. Healy, Schwartz, and Badaczewski (the “Individual Defendants”) fabricated evidence against him. (See Id. at ¶113, Pg. ID 29-32.)
2. Schwartz and Badaczewski failed to disclose exculpatory evidence in violation of their obligations under Brady v. ...

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