Case: West-Campeau v. Dunlap

2:24-cv-12751 | U.S. District Court for the Eastern District of Michigan

Filed Date: Oct. 17, 2024

Closed Date: March 25, 2026

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Case Summary

This is a class action lawsuit alleging that the Wayne County Criminal Justice Center (CJC), a new jail that opened in September 2024, was plagued by operational and administrative chaos, leading to people being held in the jail longer than was permissible. On November 17, 2024, an individual formerly detained by the CJC filed a lawsuit alleging staff shortages and computer system unavailability led to individuals being held beyond their release order. The named plaintiff in the suit was held f…

On November 17, 2024, an individual formerly detained by the CJC filed a lawsuit alleging staff shortages and computer system unavailability led to individuals being held beyond their release order. The named plaintiff in the suit was held for six days past the date of the court’s release order. The plaintiffs alleged defendants had a policy of detaining individuals for as long as fourteen days after the reason for their incarceration had ended. The plaintiffs argued this was in violation of the due process clause of the Fourteenth Amendment. The Chief of Jails of Wayne County, five employees responsible for the detention of individuals at CJC, the Wayne County Sheriff, and Wayne County were all named as defendants.

The lawsuit sought to certify a class of all persons held at the old Wayne County Jail and/or the new Wayne County Criminal Justice Center from October 14, 2021, onward who have been detained in the CJC for five or more days after the reasons for the detention have ended. The case was assigned to District Judge Mark A. Goldsmith in the U.S. District Court for the Eastern District of Michigan.

Defendants filed a motion to dismiss on December 18, 2024 pursuant to FRCP 12(b)(1), 12(b)(6), and 56. First, defendants claimed that the Court should abstain from adjudicating the 14th Amendment civil claim because of the Younger v. Harris doctrine. Second, defendants claimed that Chief Dunlap is entitled to qualified immunity on claims asserted against him in his individual capacity. Third, defendants claimed that the plaintiffs did not state a claim nor raise a genuine issue of material fact on a municipal liability claim against Wayne County.

The Court issued an order denying defendants’ motion to dismiss on February 4, 2025. The Court reasoned that under FRCP 15(a), the motion to dismiss was denied without prejudice because plaintiffs had since filed an amended complaint.

Defendants entered a second motion to dismiss, to abstain, and/or for summary judgment on March 20, 2025. Defendants argued 1) the Eleventh Amendment immunity bars plaintiffs’ Fourteenth Amendment for money damages against Wayne County, 2) quasi-judicial immunity bars the claim against Chief Dunlap, 3) the Court should abstain under the Pullman or Younger doctrine, or alternatively, 4) Chief Dunlap would be entitled to qualified immunity on the Fourteenth Amendment claims asserted against him in his individual capacity. Defendants also claimed that plaintiffs did not state a claim nor could raise a genuine issue of material fact on a municipal liability claim against Wayne County.

The Court granted the defendant's motion to dismiss on March 25, 2026. The Court found that the plaintiffs failed to establish a fundamental constitutional right to prompt release following a bond order, distinguishing this case from established bail rights. Moreover, the Court noted that there was no precedent establishing such a fundamental right and that the inmates had alternative remedies available through the state court that issued the original bond order. Additionally, the Court granted qualified immunity to individual defendants due to the lack of clearly established law. The Court also concluded that Wayne County prevailed because plaintiffs failed to plausible allege a violation under Monell which states a plaintiff may not hold a municipality vicariously liable for the unconstitutional actions of its officers. A judgment was entered on March 25, 2026.

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Summary Authors

Cara Claflin (1/4/2025)

Ana Lopez (4/19/2026)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69271387/parties/west-campeau-v-dunlap/

Judge(s)

Goldsmith, Mark Allan (Michigan)

Attorney for Plaintiff

Bonanni, Megan (Michigan)

Canepa, Danielle Young (Michigan)

Carlson, Kevin Michael (Michigan)

Elliott, Dean D. (Michigan)

Attorney for Defendant

Judge(s)

Goldsmith, Mark Allan (Michigan)

Attorney for Plaintiff

Bonanni, Megan (Michigan)

Canepa, Danielle Young (Michigan)

Carlson, Kevin Michael (Michigan)

Elliott, Dean D. (Michigan)

Attorney for Defendant

Monticciolo, Anthony (Michigan)

Stella, Davidde A. (Michigan)

Attorney Contact Information via CourtListener

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Documents in the Clearinghouse

	Document
13 2:24-cv-12751	Dismiss	Dec. 18, 2024	Dec. 18, 2024
15 2:24-cv-12751	Seal	Dec. 18, 2024	Dec. 18, 2024
19 2:24-cv-12751	Order on Motion to Dismiss AND Order on Motion to Seal	Feb. 4, 2025	Feb. 4, 2025
19 2:24-cv-12751	Order on Motion to Dismiss AND Order on Motion to Seal	Feb. 4, 2025	Feb. 4, 2025
27 2:24-cv-12751	Dismiss	March 20, 2025	March 20, 2025
37 2:24-cv-12751	Memorandum Opinion & Order	March 25, 2026	March 25, 2026

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Docket

See docket on RECAP: https://www.courtlistener.com/docket/69271387/west-campeau-v-dunlap/

Last updated April 6, 2026, 10:09 p.m.

ECF Number	Description	Date	Link Date / Link
1	COMPLAINT AND JURY DEMAND filed by Liam West-Campeau against All Defendants with Jury Demand. Plaintiff requests summons issued. Receipt No: AMIEDC-9980404 - Fee: $ 405. County of 1st Plaintiff: Macomb - County Where Action Arose: Wayne - County of 1st Defendant: Wayne. [Previously dismissed case: No] [Possible companion case(s): None] (Bonanni, Megan) (Entered: 10/17/2024)	Oct. 17, 2024	Oct. 17, 2024 RECAP
2	NOTICE of Appearance by Kevin Michael Carlson on behalf of All Plaintiffs. (Carlson, Kevin) (Entered: 10/17/2024)	Oct. 17, 2024	Oct. 17, 2024
3	SUMMONS Issued for Robert Dunlap, Raphael Washington, Wayne, County of (SHic) (Entered: 10/17/2024)	Oct. 17, 2024	Oct. 17, 2024
	Notice to Parties of Consent of a Civil Action before a Magistrate Judge Option	Oct. 17, 2024	Oct. 17, 2024
	A United States Magistrate Judge of this Court is available to conduct all proceedings in this civil action in accordance with 28 U.S.C. 636c and FRCP 73. The Notice, Consent, and Reference of a Civil Action to a Magistrate Judge form is available for download at http://www.mied.uscourts.gov (SHic)	Oct. 17, 2024	Oct. 17, 2024
4	ORDER REGARDING PROTOCOLS ON FILINGS AND COMMUNICATION WITH THE COURT - Signed by District Judge Mark A. Goldsmith. (CCie) (Entered: 10/21/2024)	Oct. 21, 2024	Oct. 21, 2024
5	CERTIFICATE of Service/Summons Returned Executed. Wayne, County of served on 11/8/2024, answer due 11/29/2024. (Bonanni, Megan) (Entered: 11/22/2024)	Nov. 22, 2024	Nov. 22, 2024
6	CERTIFICATE of Service/Summons Returned Executed. Raphael Washington served on 10/25/2024, answer due 11/15/2024. (Bonanni, Megan) (Entered: 11/22/2024)	Nov. 22, 2024	Nov. 22, 2024
7	CERTIFICATE of Service/Summons Returned Executed. Robert Dunlap served on 10/25/2024, answer due 11/15/2024. (Bonanni, Megan) (Entered: 11/22/2024)	Nov. 22, 2024	Nov. 22, 2024
8	[STRICKEN] MOTION to Dismiss MOTION TO ABSTAIN, TO DISMISS, AND/OR FOR SUMMARY JUDGMENT by Robert Dunlap, Raphael Washington, Wayne, County of. (Attachments: # 1 Index of Exhibits Index of Exhibits and Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Exhibit Exhibit 3, # 4 Exhibit Exhibit 4, # 5 Exhibit Exhibit 5, # 6 Exhibit Exhibit 6, # 7 Exhibit Exhibit 7, # 8 Exhibit Exhibit 8) (Stella, Davidde) Modified on 12/19/2024 (CCie). (Entered: 12/16/2024)	Dec. 16, 2024	Dec. 16, 2024
9	[STRICKEN] MOTION to Seal 8 MOTION to Dismiss MOTION TO ABSTAIN, TO DISMISS, AND/OR FOR SUMMARY JUDGMENT MOTION TO FILE UNDER SEAL EXHIBIT 7 TO DEFENDANTS DISPOSITIVE MOTION by Robert Dunlap, Raphael Washington, Wayne, County of. (Attachments: # 1 Index of Exhibits Index of Exhibits and Exhibit A (Redacted)) (Stella, Davidde) Modified on 12/19/2024 (CCie). (Entered: 12/16/2024)	Dec. 16, 2024	Dec. 16, 2024
10	SEALED EXHIBIT Declaration of Sergeant Britton Foreman re 8 MOTION to Dismiss MOTION TO ABSTAIN, TO DISMISS, AND/OR FOR SUMMARY JUDGMENT by Robert Dunlap, Raphael Washington, Wayne, County of. (Stella, Davidde) (Entered: 12/16/2024)	Dec. 16, 2024	Dec. 16, 2024
11	NOTICE of Appearance by Anthony Monticciolo on behalf of Robert Dunlap, Raphael Washington, Wayne, County of. (Monticciolo, Anthony) (Entered: 12/17/2024)	Dec. 17, 2024	Dec. 17, 2024
12	ORDER STRIKING 8 MOTION to Dismiss MOTION TO ABSTAIN, TO DISMISS, AND/OR FOR SUMMARY JUDGMENT filed by Raphael Washington, Wayne, County of, Robert Dunlap - Signed by District Judge Mark A. Goldsmith. (CCie) (Entered: 12/18/2024)	Dec. 18, 2024	Dec. 18, 2024
13	MOTION to Dismiss CORRECTED MOTION TO ABSTAIN, TO DISMISS, AND/OR FOR SUMMARY JUDGMENT by Robert Dunlap, Raphael Washington, Wayne, County of. (Attachments: # 1 Index of Exhibits Index of Exhibits and Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Exhibit Exhibit 3, # 4 Exhibit Exhibit 4, # 5 Exhibit Exhibit 5, # 6 Exhibit Exhibit 6, # 7 Exhibit Exhibit 7, # 8 Exhibit Exhibit 8) (Stella, Davidde) (Entered: 12/18/2024)	Dec. 18, 2024	Dec. 18, 2024 Clearinghouse
14	ORDER STRIKING DOCUMENT 9 MOTION to Seal - Signed by District Judge Mark A. Goldsmith. (CCie) (Entered: 12/18/2024)	Dec. 18, 2024	Dec. 18, 2024
15	MOTION to Seal 13 MOTION to Dismiss CORRECTED MOTION TO ABSTAIN, TO DISMISS, AND/OR FOR SUMMARY JUDGMENT CORRECTED MOTION TO FILE UNDER SEAL EXHIBIT 7 TO DEFENDANTS DISPOSITIVE MOTION by Robert Dunlap, Raphael Washington, Wayne, County of. (Stella, Davidde) (Entered: 12/18/2024)	Dec. 18, 2024	Dec. 18, 2024 Clearinghouse
16	NOTICE of Appearance by Danielle Young Canepa on behalf of All Plaintiffs. (Young Canepa, Danielle) (Entered: 01/29/2025)	Jan. 29, 2025	Jan. 29, 2025
17	AMENDED COMPLAINT with Jury Demand filed by All Plaintiffs against All Defendants. NEW PARTIES ADDED. (Bonanni, Megan) (Entered: 01/29/2025)	Jan. 29, 2025	Jan. 29, 2025
18	RESPONSE to 13 MOTION to Dismiss CORRECTED MOTION TO ABSTAIN, TO DISMISS, AND/OR FOR SUMMARY JUDGMENT filed by All Plaintiffs. (Attachments: # 1 Exhibit 1 - Vera Report and Recommendations) (Bonanni, Megan) (Entered: 01/29/2025)	Jan. 29, 2025	Jan. 29, 2025
19	ORDER DENYING DEFENDANTS' 13 Motion to Dismiss AND DENYING DEFENDANTS' 15 Motion to Seal - Signed by District Judge Mark A. Goldsmith. (CCie) (Entered: 02/04/2025)	Feb. 4, 2025	Feb. 4, 2025 Clearinghouse
20	MOTION to Strike 17 Amended Complaint MOTION TO STRIKE PLAINTIFFS AMENDED COMPLAINT BY DEFENDANTS CHIEF ROBERT DUNLAP, THE WAYNE COUNTY SHERIFF, AND WAYNE COUNTY by Robert Dunlap, Raphael Washington, Wayne, County of. (Attachments: # 1 Index of Exhibits Index of Exhibits and Exhibit 1, # 2 Exhibit Exhibit 2) (Stella, Davidde) (Entered: 02/05/2025)	Feb. 5, 2025	Feb. 5, 2025
21	NOTICE of Appearance by Dean D. Elliott on behalf of All Plaintiffs. (Elliott, Dean) (Entered: 02/06/2025)	Feb. 6, 2025	Feb. 6, 2025
22	NOTICE OF REMOTE HEARING on 20 MOTION to Strike 17 Amended Complaint MOTION TO STRIKE PLAINTIFFS AMENDED COMPLAINT BY DEFENDANTS CHIEF ROBERT DUNLAP, THE WAYNE COUNTY SHERIFF, AND WAYNE COUNTY - Motion Hearing set for 2/18/2025 03:30 PM before District Judge Mark A. Goldsmith - \|Remote Access Phone Number: +1 646 828 7666 US (New York) and Meeting ID: 160 755 4123\| (CCie) (Entered: 02/10/2025)	Feb. 10, 2025	Feb. 10, 2025
	Text-Only Order	Feb. 10, 2025	Feb. 10, 2025
	TEXT-ONLY ORDER: Plaintiff must file a response to the pending motion to strike at Dkt. 20 - (Plaintiff's Response due by 2/14/2025) - Entered by District Judge Mark A. Goldsmith. (CCie)	Feb. 10, 2025	Feb. 10, 2025
23	RESPONSE to 20 MOTION to Strike 17 Amended Complaint MOTION TO STRIKE PLAINTIFFS AMENDED COMPLAINT BY DEFENDANTS CHIEF ROBERT DUNLAP, THE WAYNE COUNTY SHERIFF, AND WAYNE COUNTY filed by All Plaintiffs. (Attachments: # 1 Exhibit 3 - emails, # 2 Exhibit 2 - email and proposed order, # 3 Exhibit 3 - submission of proposed order) (Carlson, Kevin) (Entered: 02/13/2025)	Feb. 13, 2025	Feb. 13, 2025
24	REPLY to Response re 20 MOTION to Strike 17 Amended Complaint MOTION TO STRIKE PLAINTIFFS AMENDED COMPLAINT BY DEFENDANTS CHIEF ROBERT DUNLAP, THE WAYNE COUNTY SHERIFF, AND WAYNE COUNTY REPLY IN SUPPORT OF MOTION TO STRIKE PLAINTIFFS AMENDED COMPLAINT filed by Robert Dunlap, Raphael Washington, Wayne, County of. (Stella, Davidde) (Entered: 02/17/2025)	Feb. 17, 2025	Feb. 17, 2025
	Minute Entry for remote proceedings before District Judge Mark A. Goldsmith: Motion Hearing held on 2/18/2025 re 20 MOTION to Strike 17 Amended Complaint MOTION TO STRIKE PLAINTIFFS AMENDED COMPLAINT BY DEFENDANTS CHIEF ROBERT DUNLAP, THE WAYNE COUNTY SHERIFF, AND WAYNE COUNTY filed by Raphael Washington, Wayne, County of, Robert Dunlap - Disposition: Motion denied. (Court Reporter: David Yarbrough) (CCie)	Feb. 18, 2025	Feb. 18, 2025
25	ORDER DENYING DEFENDANTS' 20 Motion to Strike - Signed by District Judge Mark A. Goldsmith. (CCie) (Entered: 03/12/2025)	March 12, 2025	March 12, 2025
26	Ex Parte MOTION extension of page limitations EX PARTE MOTION TO EXCEED THE PAGE LIMITS by Robert Dunlap, Raphael Washington, Wayne, County of. (Attachments: # 1 Exhibit Exhibit A Proposed Brief) (Stella, Davidde) (Entered: 03/19/2025)	March 19, 2025	March 19, 2025
27	Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT by Robert Dunlap, Raphael Washington, Wayne, County of. (Attachments: # 1 Index of Exhibits Index of Exhibits and Exhibit 1, # 2 Exhibit Exhibit 2 to be filed under seal, # 3 Exhibit Exhibit 3, # 4 Exhibit Exhibit 4, # 5 Exhibit Exhibit 5, # 6 Exhibit Exhibit 6, # 7 Exhibit Exhibit 7, # 8 Exhibit Exhibit 8, # 9 Exhibit Exhibit 9, # 10 Exhibit Exhibit 10, # 11 Exhibit Exhibit 11, # 12 Exhibit Exhibit 12, # 13 Exhibit Exhibit 13, # 14 Exhibit Exhibit 14) (Stella, Davidde) (Entered: 03/20/2025)	March 20, 2025	March 20, 2025 Clearinghouse
28	MOTION to Seal 27 Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT MOTION TO FILE UNDER SEAL EXHIBIT 2 TO DEFENDANTS DISPOSITIVE MOTION by Robert Dunlap, Raphael Washington, Wayne, County of. (Attachments: # 1 Index of Exhibits Index of Exhibits and Exhibit A) (Stella, Davidde) (Entered: 03/20/2025)	March 20, 2025	March 20, 2025
29	SEALED EXHIBIT Sealed Exhibit 2 re 27 Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT, 28 MOTION to Seal 27 Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT MOTION TO FILE UNDER SEAL EXHIBIT 2 TO DEFENDANTS DISPOSITIVE MOTION by Robert Dunlap, Raphael Washington, Wayne, County of. (Stella, Davidde) (Entered: 03/20/2025)	March 20, 2025	March 20, 2025
	TEXT-ONLY ORDER granting 26 Motion for an Extension of Pages - Entered by District Judge Mark A. Goldsmith. (CCie)	April 3, 2025	April 3, 2025
	Order on Motion - Free	April 3, 2025	April 3, 2025
30	MOTION for Extension of Time to File Response/Reply as to 27 Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT by All Plaintiffs. (Carlson, Kevin) (Entered: 04/08/2025)	April 8, 2025	April 8, 2025
	Order on Motion to Seal	April 8, 2025	April 8, 2025
	TEXT-ONLY ORDER granting 28 Motion to Seal - Entered by District Judge Mark A. Goldsmith. (CCie)	April 8, 2025	April 8, 2025
31	ORDER granting 30 Motion for Extension of Time to File Response/Reply re 27 Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT - Response due by 4/25/2025 -. Signed by District Judge Mark A. Goldsmith. (CCie) (Entered: 04/10/2025)	April 10, 2025	April 10, 2025
32	RESPONSE to 27 Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT filed by All Plaintiffs. (Carlson, Kevin) (Entered: 04/24/2025)	April 24, 2025	April 24, 2025
33	STIPULATED ORDER Extending Time to File a Reply re 27 Second MOTION to Dismiss. (Reply due by 5/15/2025) Signed by District Judge Mark A. Goldsmith. (KCas) (Entered: 05/07/2025)	May 7, 2025	May 7, 2025
34	Ex Parte MOTION extension of page limitations EX PARTE MOTION TO EXCEED THE PAGE LIMITS by Robert Dunlap, Raphael Washington, Wayne, County of. (Attachments: # 1 Exhibit Exhibit A) (Stella, Davidde) (Entered: 05/15/2025)	May 15, 2025	May 15, 2025
35	REPLY to Response re 27 Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT REPLY IN SUPPORT MOTION TO DISMISS, TO ABSTAIN, OR FOR SUMMARY JUDGMENT filed by Robert Dunlap, Raphael Washington, Wayne, County of. (Stella, Davidde) (Entered: 05/21/2025)	May 21, 2025	May 21, 2025
	TEXT-ONLY ORDER GRANTING Defendants' 34 Ex Parte Motion to Exceed the Page Limits. Issued by District Judge Mark A. Goldsmith. (JHea) Modified on 5/22/2025 (JHea).	May 22, 2025	May 22, 2025
	Text-Only Order AND ~Util - Terminate Motions	May 22, 2025	May 22, 2025
36	NOTICE OF REMOTE HEARING on 27 Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT: Motion Hearing set for 11/18/2025 01:30 PM before District Judge Mark A. Goldsmith. \|Remote Access Phone Number: +1 (646) 828-7666 and Meeting ID: 161 265 7113\| (JHea) (Entered: 11/10/2025)	Nov. 10, 2025	Nov. 10, 2025
	Minute Entry for remote proceedings before District Judge Mark A. Goldsmith: Motion Hearing held on 11/18/2025 re 27 Second MOTION to Dismiss MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT filed by Raphael Washington, Wayne, County of, Robert Dunlap Disposition: Motion taken under advisement (Court Reporter: David Yarbrough) (JHea)	Nov. 18, 2025	Nov. 18, 2025
37	OPINION & ORDER GRANTING DEFENDANTS' 27 MOTION TO DISMISS, TO ABSTAIN, AND/OR FOR SUMMARY JUDGMENT. Signed by District Judge Mark A. Goldsmith. (JHea) (Entered: 03/25/2026)	March 25, 2026	March 25, 2026 Clearinghouse
38	JUDGMENT. Signed by District Judge Mark A. Goldsmith. (JHea) (Entered: 03/25/2026)	March 25, 2026	March 25, 2026

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Case Details

State / Territory:

Michigan

Case Type(s):

Jail Conditions

Key Dates

Filing Date: Oct. 17, 2024

Closing Date: March 25, 2026

Case Ongoing: No reason to think so

Plaintiffs

Plaintiff Description:

An individual formerly detained by the CJC who was held six days past his release order. The lawsuit sought to certify a class of all persons held at the old Wayne County Jail and/or the new Wayne County Criminal Justice Center from October 14, 2021, onward who have been detained in the CJC for five or more days after the reasons for the detention have ended.

Public Interest Lawyer: No

Filed Pro Se: No

Class Action Sought: Yes

Class Action Outcome: Pending

Defendants

County

Chief of Jails of Wayne County

Wayne County

Wayne County Sherif

Defendant Type(s):

Jurisdiction-wide

Law-enforcement