The U.S. Court of Appeals for the Sixth Circuit has affirmed a lower court's dismissal of civil rights claims filed by Brian W. Benderoff against nine law enforcement officers, concluding a case that raised questions about federal versus state authority in airport law enforcement actions.
In an opinion filed Jan. 13, 2026, a three-judge panel consisting of Circuit Judges Gibbons, Stranch, and Davis upheld the U.S. District Court for the Eastern District of Michigan's ruling in *Benderoff v. Johansen* (6th Cir. 2026). Judge Jane B. Stranch wrote the opinion for the court.
Benderoff had appealed the dismissal of his claims alleging unlawful detention and malicious prosecution under the Fourth, Fifth, and Fourteenth Amendments, as well as under 42 U.S.C. § 1983, the federal civil rights statute that allows individuals to sue state and local officials for constitutional violations.
The case stems from a June 23, 2016 incident at Detroit Airport where Benderoff and a friend were detained by multiple law enforcement officers. The defendants named in the lawsuit include Erik Johansen of the Wayne County Airport Authority, Jeffrey Adamisin of the Taylor Police Department, and Joseph Presley, along with six other officers: Michael Williams, Brian Helmerson, Mark Vaughan, Devallons Desmarets, Jerome Deaven, and Chris Walter.
The central legal issue in the case revolved around whether the defendant officers were acting under color of federal law or state law during the detention. This distinction is crucial in civil rights litigation because it determines which legal remedies are available to plaintiffs and what standards courts apply when evaluating the claims.
Benderoff argued that the district court erred in determining that the defendants were acting under color of federal, rather than state, law. He also contended that the lower court incorrectly found that no implied cause of action existed to sue federal actors in this context. Additionally, Benderoff appealed the district court's denial of his motion seeking reasonable service-related expenses.
The distinction between federal and state action is significant in constitutional law. When law enforcement officers act under state authority, plaintiffs can typically pursue claims under Section 1983, which provides a well-established avenue for civil rights litigation. However, when officers act under federal authority, the legal landscape becomes more complex, and plaintiffs may need to rely on different legal theories or face additional hurdles in pursuing their claims.
Airport law enforcement presents particular complications because multiple jurisdictions and agencies often work together in these environments. The Wayne County Airport Authority, Taylor Police Department, and other agencies represented among the defendants illustrate the multi-jurisdictional nature of airport security and law enforcement operations.
The Fourth Amendment protects against unreasonable searches and seizures, while the Fifth Amendment includes due process protections, and the Fourteenth Amendment extends due process requirements to state actions. In cases involving alleged unlawful detention and malicious prosecution, these constitutional provisions serve as the foundation for civil rights claims.
Section 1983 claims require plaintiffs to demonstrate that defendants acted under color of state law while violating their constitutional rights. The "under color of law" requirement distinguishes between private conduct and official action that can give rise to federal civil rights liability.
The Sixth Circuit's affirmance suggests the appeals court agreed with the district court's analysis of the federal versus state law distinction and the availability of remedies against the defendant officers. The court's decision not to recommend the opinion for publication indicates it likely applied established legal principles rather than breaking new ground in civil rights law.
For Benderoff, the affirmance represents the conclusion of his federal court challenge to the 2016 detention incident. The ruling also denied his request for service-related expenses, adding a procedural component to the substantive constitutional claims.
The case highlights ongoing tensions in civil rights litigation involving law enforcement conduct in complex jurisdictional environments like airports. As security measures continue to evolve and multiple agencies coordinate their efforts, questions about accountability and available legal remedies for alleged constitutional violations remain relevant for both law enforcement practices and individual rights protection.
The decision joins other Sixth Circuit precedents addressing the scope of civil rights remedies and the application of constitutional protections in law enforcement contexts. While not recommended for publication, the ruling provides guidance for similar cases involving multi-jurisdictional law enforcement operations and questions about federal versus state authority in civil rights litigation.