SEAN HART; TIFFANY GUZMAN v. CITY OF GRAND RAPIDS, MICHIGAN; PHILLIP REININK, BRAD BUSH, and BENJAMIN JOHNSON, Officers, in their individual and official capacities - Articles

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SEAN HART; TIFFANY GUZMAN v. CITY OF GRAND RAPIDS, MICHIGAN; PHILLIP REININK, BRAD BUSH, and BENJAMIN JOHNSON, Officers, in their individual and official capacities

Posted by: Azya Thornton on May 15, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Christopher P. Desmond, JOHNSON LAW, PLC, Detroit, Michigan, for Appellants.

Attorneys 2: ARGUED: Douglas J. Curlew, CUMMINGS, MCCLOREY, DAVIS & ACHO, P.L.C., Livonia, Michigan, for Appellees City of Grand Rapids and Officers Bush and Johnson. Marcelyn A. Stepanski, ROSATI, SCHULTZ JOPPICH & AMTSBUECHLER PC, Farmington, Hills, Michigan, for Officer Reinink.

Attorneys 3: ON BRIEF: Christopher P. Desmond, JOHNSON LAW, PLC, Detroit, Michigan, for Appellants. Douglas J. Curlew, CUMMINGS, MCCLOREY, DAVIS & ACHO, P.L.C., Livonia, Michigan, for Appellees City of Grand Rapids and Officers Bush and Johnson.

Attorneys 4: ON BRIEF: Marcelyn A. Stepanski, ROSATI, SCHULTZ JOPPICH & AMTSBUECHLER PC, Farmington Hills, Michigan, for Officer Reinink.

Judge(s): GILMAN, STRANCH, and LARSEN, Circuit Judges

Court Appealed: United States District Court for the Western District of Michigan at Grand Rapids

JANE B. STRANCH, Circuit Judge. Sean Hart and Tiffany Guzman appeal the district court’s dismissal of their excessive force claims under 42 U.S.C. § 1983 against the City of Grand Rapids, Sergeant Brad Bush, and Officers Benjamin Johnson and Phillip Reinink. Hart and Guzman claim that the officers employed excessive force during a 2020 Black Lives Matter demonstration in Grand Rapids and that the City ratified this unlawful conduct. The officers moved for summary judgment based on qualified immunity, and the City moved for summary judgment based on the failure of Hart and Guzman to establish municipal liability. The district court granted the motions, dismissing the federal claims and declining to exercise jurisdiction over Hart and Guzman’s state law claims. For the reasons that follow, we AFFIRM the grant of summary judgment based on qualified immunity as to Officer Johnson and Sergeant Bush and AFFIRM the grant of summary judgment in favor of the City, but we REVERSE the grant of summary judgment based on qualified immunity as to Officer Reinink, and REMAND for further proceedings on that claim.

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