Grant of Habeas Relief Reversed, Plus Civil Rights Suit Involving Drunk Driving Arrest

In Wynne v. Renico, No. 03-2319, the Sixth Circuit faced a challenge to the district court's grant of defendant's petition for habeas relief from his murder conviction and a life sentence.  In reversing the district court's judgment granting relief, the court held that Fed. Rule 404(b) applies to all propensity evidence, whether used to show that the defendant or another individual acted in conformity with their prior misconduct, and the Sixth Amendment right to present a complete defense does not imply a right to offer evidence that is otherwise inadmissible under the standard rules of evidence.  

Miller v. Sanilac County, No. 09-1340, concerned a plaintiff's 42 U.S.C. section 1983 suit claiming various constitutional violations against him during a traffic stop and arrest for several traffic code violations, civil infractions, including drunk driving, all of which were dismissed when plaintiff's blood alcohol level was determined to be 0.00%.

The court affirmed the portion of the district court's judgment in holding that, the grant of defendants' motion for summary judgment on malicious prosecution claims with respect to four of the seven tickets was properly granted because they constituted civil infractions, not criminal prosecutions.  Also, the court held that the grant of summary judgment with respect to a claim for unlawful search and seizure for a second blood test, and a state claim of gross negligence and municipal liability against a county were properly granted.

However, the court reversed the district court's grant of summary judgment with respect to federal claims of malicious prosecution for criminal charges, unlawful arrest, and excessive force are reversed, as well as the grant of summary judgment with respect to state law claims of false arrest, false imprisonment, malicious prosecution, assault and battery. 

Related Resources:

• Full text of Wynne v. Renico
• Full text of Miller v. Sanilac County