The Sixth Circuit Court of Appeals issued a published opinion February 12 in a civil rights case arising from the 2022 murder of Linda Henry by her next-door neighbor in Michigan. The court designated the decision for publication, indicating its potential significance as legal precedent.
The case, *Henry v. Blank*, involves a lawsuit filed by McCord Henry as personal representative of his mother's estate against Benzie County and four sheriff's deputies: Martin Blank, Troy Packard, James Kosiboski, and Matthew Weaver. The estate alleges that the defendants' actions contributed to Linda Henry's death through what the court record describes as "selective" enforcement practices.
According to court documents, Linda Henry was murdered in February 2022 by Jeffrey Stratton, her next-door neighbor. The estate's lawsuit claims that the defendants' conduct or failure to act properly contributed to the circumstances that led to Henry's death.
The three-judge panel consisting of Circuit Judges Ronald Lee Gilman, Julia Smith Gibbons Griffin, and Chad A. Murphy heard the appeal from the U.S. District Court for the Western District of Michigan at Grand Rapids. District Judge Hala Y. Jarbou presided over the lower court proceedings in the case, which was filed as No. 1:25-cv-00113.
Judge Ronald Lee Gilman authored the circuit court opinion, though the full content of the ruling and its specific holdings were not detailed in the available court filing. The case represents an appeal from the district court's decision, suggesting the lower court may have ruled against the estate's claims.
The estate was represented by Jacob R. Goodman and Bailor Bell of The Fierberg National Law Group, PLLC, based in Traverse City, Michigan, along with Douglas E. Fierberg. The law firm specializes in civil rights and personal injury cases. The defendants were represented by Douglas J. Curlew of Cummings, McClorey, Davis & Acho, P.L.C., located in Livonia, Michigan.
The Sixth Circuit's decision to recommend the case for publication under Internal Operating Procedure 32.1(b) suggests the court believes the ruling addresses legal issues of broader significance that could guide future cases. Published decisions carry precedential weight and become part of the body of binding case law that lower courts must follow within the circuit's jurisdiction.
The Sixth Circuit covers federal appeals from Michigan, Ohio, Kentucky, and Tennessee. Cases recommended for publication typically involve novel legal questions, clarification of existing law, or issues of public importance that warrant broader judicial and legal community attention.
Civil rights lawsuits against law enforcement agencies and officers often involve claims under Section 1983 of the Civil Rights Act, which allows individuals to sue government officials who violate their constitutional rights while acting under color of law. Such cases frequently raise questions about qualified immunity, which can protect government officials from liability unless they violated clearly established constitutional rights.
The timing of the case filing in 2025, approximately three years after Henry's murder, suggests the estate may have pursued criminal proceedings or other legal avenues before filing the federal civil rights lawsuit. Federal civil rights claims often follow completion of state criminal cases.
Benzie County is located in northwestern Michigan along Lake Michigan's shoreline. The county seat is Beulah, and the area includes several small communities and rural areas where neighbor disputes can escalate without adequate law enforcement intervention.
The case raises questions about law enforcement's duty to protect citizens from known threats and the potential liability when officers fail to take appropriate action in domestic or neighbor disputes. Courts have generally held that police have no specific constitutional duty to protect individuals, but exceptions may apply when officers create or increase danger through their actions.
The selective enforcement allegation suggests the estate may have argued that the defendants treated Henry's situation differently than they would have treated others, potentially raising equal protection issues under the Fourteenth Amendment. Such claims require showing that similarly situated individuals were treated more favorably.
The published nature of this decision means it will be available to guide attorneys, judges, and law enforcement agencies in similar cases involving claims against police for failure to prevent harm to citizens. The ruling may clarify standards for liability in cases where private violence occurs after law enforcement contact or intervention.
The specific outcome of the appeal and the court's reasoning will provide important guidance for future civil rights cases involving law enforcement's response to threats of violence between neighbors or domestic parties. Legal practitioners and law enforcement agencies will likely study this decision for its implications regarding official liability and protective duties.