Butler v. City of Detroit, No. 18-1605 (6th Cir. 2019)
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The day after a controlled buy, Detroit police officer Benitez obtained a warrant to search 12011 Bramell. His affidavit stated that a reliable confidential informant had been at two Burnette addresses and “12011 BRAMELL (the target location) and that a certain drug dealer had been selling cocaine and heroin out of 9542 Burnette for several months. Burnette Street and Bramell are eight miles apart. Benitez could not have simultaneously observed the locations as stated in the affidavit. Detroit police executed the warrant at Bramell, which is owned by Butler, a retiree with no prior convictions or links to drug operations. Officers asked for Butler's ID, which Butler provided; he stated he had a concealed pistol license and was carrying a weapon. Butler was handcuffed. Sergeant Meadows “slammed” him “against the wall.” Butler had sustained a serious neck injury during military service, resulting in a spinal fusion operation and disability-based retirement. The “slam” reinjured him. From the house, the police recovered $3,702 cash, weapons, a bulletproof vest, and ibuprofen pills. The state did not charge Butler, who filed a 42 U.S.C. 1983 lawsuit.
The Sixth Circuit affirmed the denial of qualified immunity to Meadows on the excessive force claim and reversed the denial of qualified immunity to Benitez on the false affidavit claim. Assaulting an unarmed, compliant individual is a clearly-established violation of the Fourth Amendment. Removing alleged falsehoods, Benitez had not personally seen suspicious activity at Bramell but he corroborated what the informant stated about the Burnette addresses. Officers need not corroborate every detail provided by an informant to show the informant’s reliability. Even without personally observing any drug activity at Bramell, Benitez put enough in the affidavit for a magistrate to conclude that the informant—who was correct about everything else—would be right that Bramell was a “stash house.”
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