Danny Burton spent thirty-two years in prison after he was wrongfully convicted of first-degree murder. Detective Ronald Sanders, employed by the city of Detroit, Michigan, used witness manipulation and intimidation tactics while investigating a shooting, which led to Burton's conviction in state court in 1987. After witnesses recanted their false testimony and details of Detective Sanders's misconduct came to light, Burton was released from prison, and his conviction was vacated in December 2019. Following Burton's release, his sons, Danny Lamont Chambers and Dontell Rayvon-Eddie Smith, filed suit in the United States District Court for the Eastern District of Michigan against Detective Sanders and the city of Detroit, alleging violation of their constitutional right to family integrity because the wrongful conviction and incarceration of Burton deprived them of their father from childhood through adulthood. In other words, Burton's sons claimed that because Burton's rights were violated, their rights were also inevitably violated.
The Eastern District of Michigan dismissed Chambers and Smith's claims against both Sanders and the city. The court refused to recognize a violation of the due process right to family integrity “when a party is indirectly harmed by a constitutional tort against a family member.” Chambers and Smith appealed the Eastern District of Michigan's decision and reasserted their argument that the “right of familial association extends to cases where the state has wrongfully incarcerated a parent for a significant period.” The United States Court of Appeals for the Sixth Circuit held that Chambers and Smith's claims were properly dismissed because Sanders did not act with a culpable state of mind specifically directed at harming the family relationship when he procured Burton's wrongful conviction and incarceration.
The noted case was a matter of first impression for the Sixth Circuit. It also considered an issue on which sister circuits are currently split in their interpretations. This case is significant because it set a binding Sixth Circuit precedent for an important group of federal cases: constitutional claims of the state violating the people's fundamental right to family integrity. Specifically, this decision affects family members' ability to bring claims that their right of familial association has been violated by wrongful action done to another family member. Such a decision could have a potentially significant impact on the court's docket and also sends a message of what the court is willing to prioritize in terms of policy. The jurisdictional split on this issue heavily favors one side, so the Sixth Circuit faced a crossroads: either rely on the majority of sister circuits or take a stand to pave a new path in constitutional interpretation.
This Note provides a look into substantive due process claims under 42 U.S.C. § 1983, and it explains how the Sixth Circuit erroneously disregarded United States Supreme Court precedent while incorrectly relying on sister circuit interpretation to decide that Chambers and Smith's claims should be dismissed. Part II provides necessary background of applicable law (including the relevant circuit split) that builds the foundation for understanding § 1983 claims, particularly in the context of the due process right to family integrity. Part III explores how the majority and dissent of the noted case utilize the relevant precedent to make arguments on each side of the circuit split. Part IV explains the different interpretations of § 1983 claims for family integrity and ultimately determines that the Sixth Circuit erroneously imposed a culpability/state-of-mind requirement on a § 1983 claim and should have instead allowed Chambers and Smith's claims to survive dismissal. Part V briefly concludes.
About the Author
Amanda S. Kim, J.D. Candidate 2025, Tulane University Law School; B.A. 2022, University of Virginia.
Citation
98 Tul. L. Rev. 741