Wire
Vacated murder conviction can’t bar civil-rights suit
The Sixth Circuit said Michigan law gives an undone criminal judgment no preclusive force, even after a stipulation. That keeps Marvin Cotton and Anthony Legion free to press claims tied to the old Detroit case.
Detroit officers cannot use Marvin Cotton and Anthony Legion’s vacated murder conviction to block their civil-rights lawsuit, the Sixth Circuit said. The court said the undone conviction and the earlier rulings tied to it no longer bind the men in civil court.
The judges also rejected Donald Hughes’s argument that it made a difference that the vacatur came by stipulation. In the court’s view, even that kind of agreed-upon undoing leaves the conviction without preclusive effect.
The shield falls away
The doctrine at the center of the case is issue preclusion, the rule that keeps a question from being relitigated after a court has already decided it. But Michigan law, the Sixth Circuit said, does not let a vacated judgment do that work. Once the conviction is vacated, it cannot be treated as a binding answer in later litigation.
The same rule reached the earlier criminal rulings that supported the conviction. So the officers could not reach back to the old case and use those interlocutory decisions as a shortcut around the civil-rights claims now pending against them.
Why that matters now
For Cotton and Legion, the ruling means their lawsuit survives a defense that might otherwise have ended it before the merits were ever heard. That matters in wrongful-conviction litigation, where the old criminal case can sometimes loom large enough to decide the civil one before testimony even begins.
By refusing to give the vacated conviction any preclusive force, the court kept the courthouse open and the fight focused where the men wanted it, on the substance of their claims rather than on a case that Michigan law no longer lets control the outcome.