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CITY OF DETROIT, MICHIGAN, et al.,
| No. 19-1555|
Appeal from the United States District Court
for the Eastern District of Michigan at Flint.
No. 4:12-cv-11679—Gershwin A. Drain, District Judge.
Argued: May 5, 2020
Decided and Filed: May 13, 2020
Before: MERRITT, SUHRHEINRICH, and SUTTON, Circuit Judges.
SUTTON, Circuit Judge. Police officers meant to arrest Roderick Siner, who goes by the
alias Marvin Seals. They arrested Marvin Seales instead. Fifteen days later, the State realized
the mistake and released Seales. Seales sued Thomas Zberkot (the police officer who arrested
him), the City of Detroit (which held him for the first two days), and Wayne County (which held
him in jail for about thirteen days after that). By the time of trial, only Officer Zberkot remained
in the case, and the jury awarded Seales $3.5 million for wrongful detention under federal and
state law. Because Officer Zberkot handled the case for fewer than three hours and because our
prior decision in this case held as a matter of law that there was probable cause to arrest Seales
given the similarities between him and Seals, we must reverse.