LARRY SMITH v. WAYNE COUNTY, MICHIGAN; ROBERT J. DONALDSON - Articles

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LARRY SMITH v. WAYNE COUNTY, MICHIGAN; ROBERT J. DONALDSON

Posted by: Azya Thornton on Aug 5, 2025

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Jarrett Adams, THE LAW OFFICE OF JARRETT ADAMS, PLLC, New York, New York, for Appellant.

Attorneys 2: ARGUED: Josephine A. DeLorenzo, PLUNKETT COONEY, Bloomfield Hills, Michigan, for Appellees.

Attorneys 3: ON BRIEF: Jarrett Adams, THE LAW OFFICE OF JARRETT ADAMS, PLLC, New York, New York, Pamela L. Campbell, RICE LAW PLLC, Eastpointe, Michigan, for Appellant.

Attorneys 4: ON BRIEF: Josephine A. DeLorenzo, PLUNKETT COONEY, Bloomfield Hills, Michigan, for Appellees.

Judge(s): THAPAR, BUSH, and LARSEN, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Detroit

BUSH, Circuit Judge. After prosecutors agreed to have his murder conviction thrown out, Larry Smith sued Wayne County and Robert Donaldson. Smith claims that his conviction resulted from an elaborate scheme designed by police and prosecutors to elicit false testimony from jailhouse informants to help secure criminal convictions. He alleges that Donaldson, one of the prosecutors in his case, is liable because he actively participated in eliciting false testimony from a key witness. And he maintains Wayne County is also on the hook because it had a policy or custom of encouraging the nefarious activities. The district court granted summary judgment in favor of Donaldson and Wayne County. We AFFIRM. Donaldson is entitled to absolute prosecutorial immunity because Smith seeks to hold him liable for his conduct as an advocate preparing for trial. And Smith released his claim against Wayne County when he accepted a settlement under Michigan’s Wrongful Imprisonment Compensation Act. Both Defendants are entitled to summary judgment.

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