The U.S. Court of Appeals for the Sixth Circuit affirmed Tuesday a district court's denial of qualified immunity to two Detroit police officers accused of orchestrating a scheme that led to the wrongful conviction of Lacino Hamilton, who spent 26 years in prison for a murder he did not commit.
The appeals court ruled that former Detroit Police Department detective James Fleming and DPD Homicide Section supervisor William Rice cannot claim qualified immunity protection in Hamilton's civil rights lawsuit stemming from his 1991 conviction for the murder of his foster mother, Willa Bias.
Hamilton's conviction was vacated after the Wayne County Prosecutor's Conviction Integrity Unit determined he was unfairly convicted. The conviction had rested primarily on testimony from Oliver Cowan, described in court documents as "a frequent detainee in the holding area on the ninth floor of the Detroit Police Department headquarters."
According to the lawsuit, the ninth floor of DPD headquarters held special significance as the alleged location where Fleming and Rice participated in a scheme to provide special treatment to prisoners in exchange for falsified testimony. The case highlights ongoing concerns about police misconduct in securing convictions through questionable witness testimony.
The Sixth Circuit panel, consisting of Circuit Judges Alice Batchelder Boggs, John K. Bush, and Chad Readler, unanimously affirmed the Eastern District of Michigan's summary judgment ruling. Judge Bush authored the opinion for the three-judge panel.
"We find no reversible error and AFFIRM," the court wrote in its opinion filed Jan. 14, 2026. The case number is 25-1386, and the opinion was marked "NOT RECOMMENDED FOR PUBLICATION," indicating it will not serve as binding precedent for future cases.
Qualified immunity typically protects government officials from civil lawsuits unless they violated clearly established statutory or constitutional rights that a reasonable person would have known about. The doctrine has become a focal point in police accountability debates, with critics arguing it shields officers from consequences for misconduct.
The district court's denial of qualified immunity at the summary judgment stage suggests the court found sufficient evidence that Fleming and Rice's alleged conduct violated clearly established constitutional rights. The Sixth Circuit's affirmation of that ruling means Hamilton's lawsuit can proceed to trial.
Hamilton's case represents one of numerous wrongful conviction lawsuits filed against police departments across the country. The involvement of Wayne County's Conviction Integrity Unit in overturning his conviction adds credibility to claims of prosecutorial error or misconduct in the original case.
Conviction integrity units have become increasingly common in prosecutor's offices nationwide, serving as internal watchdogs to review potentially wrongful convictions. Wayne County established its unit to examine cases where new evidence or procedural problems may have led to incorrect verdicts.
The allegations against Fleming and Rice center on what Hamilton describes as a systematic scheme to coerce false testimony from jail detainees. Such arrangements, sometimes called "jailhouse informant" programs, have drawn criticism from civil rights advocates who argue they incentivize perjury and lead to wrongful convictions.
The case also highlights the challenges facing individuals seeking accountability after wrongful convictions. Even after having their convictions overturned, exonerees often face significant hurdles in civil litigation against the officers and prosecutors involved in their cases.
Federal civil rights lawsuits under 42 U.S.C. Section 1983 provide one avenue for seeking damages, but qualified immunity and other legal doctrines frequently limit recovery options. The Sixth Circuit's ruling represents a victory for Hamilton in overcoming one of those barriers.
The opinion's "NOT RECOMMENDED FOR PUBLICATION" designation means it will not establish binding precedent for future qualified immunity cases in the Sixth Circuit. However, it does provide Hamilton with the opportunity to proceed with his claims against the officers in district court.
Detroit has faced numerous wrongful conviction cases over the decades, with some resulting in substantial settlements. The city's police department and prosecutor's office have implemented various reforms in response to documented problems with investigations and prosecutions.
The case now returns to the Eastern District of Michigan, where Hamilton will have the opportunity to present his claims to a jury. The district court will oversee discovery proceedings and ultimately determine whether Fleming and Rice violated Hamilton's constitutional rights during the investigation that led to his conviction.
For Hamilton, who lost more than two decades of his life to wrongful imprisonment, the ruling represents progress toward potential accountability for the officers he alleges were responsible for his ordeal. The case serves as a reminder of the lasting consequences of police misconduct and the importance of robust oversight mechanisms in the criminal justice system.