Law360 (June 11, 2026, 7:53 PM EDT) -- A Detroit area police detective did not violate clearly established law in how he handled a photo lineup or by failing to flag another robbery suspect before a later-exonerated man's conviction, a Michigan federal judge has ruled, throwing out the man's civil rights suit. 

U.S. District Judge Robert J. White on Wednesday granted summary judgment to Eastpointe Police Detective Matthew Hambright and denied Mack Howell's cross-motion for partial summary judgment in a suit alleging Hambright withheld exculpatory evidence and helped cause Howell's armed robbery conviction in 2016.

Howell spent about six years in prison before the Macomb County Prosecutor's Office agreed in 2023 to vacate his conviction after a review prompted by the University of Michigan Innocence Clinic. 

Howell alleged Hambright violated his 14th Amendment rights by using an unduly suggestive photo array and by failing to disclose information about another man, Albert Arthur Jr., who admitted to a string of 7-Eleven robberies in lower Macomb County in 2014. 

But Judge White said the record did not support Howell's claims. 

"Nothing in this record indicates that Hambright possessed any evidence linking Arthur to the April 3 robbery," Judge White wrote. 

The case stems from an April 3, 2014, robbery at a 7-Eleven in Eastpointe, Michigan. 

The robber carried an empty cardboard container as though it concealed a weapon, ordered the clerk to open the register and fled after taking the cash, according to the case background in Wednesday's ruling. 

Police later recovered a beer can and straw near the store, and DNA testing linked a male sample from those items to Howell, according to the ruling. The store clerk, Rosalyn Gaston, later identified Howell in a photo array after initially selecting someone else. 

Howell argued the lineup was suggestive because Hambright asked Gaston whether she was sure of her initial selection before she changed her answer and selected Howell. He also argued his photo stood out because of his eyes. 

Judge White rejected both arguments, finding the array showed men of similar race, build, complexion, age and facial hair and did not steer Gaston toward Howell. 

"So there was no material, distinguishing characteristic that drew Gaston's attention to Howell's image or singled him out in a way that confirmed her previous description of the perpetrator," Judge White said. 

Hambright's follow-up questions were not improper, Judge White said, because he asked Gaston to confirm both her initial choice and her later identification of Howell. 

Howell alleged he wasn't given potentially exculpatory evidence, a violation of the standard set by the U.S. Supreme Court in Brady v. Maryland . Judge White said information about Arthur was too remote to qualify as clearly exculpatory evidence. Arthur admitted to several 7-Eleven robberies, including an Aug. 20, 2014, robbery at same Eastpointe store, but denied committing the April 3 robbery.

The judge said no physical evidence, forensic evidence or eyewitness testimony tied Arthur to the April robbery. 

The only thing that connected Arthur to the April 3 robbery was his later robbery spree, the fact that he robbed the same store months later and his general physical similarity to the suspect, the judge wrote. 

Those facts, the court said, could not overcome Howell's DNA at the scene, Gaston's identification and Arthur's denial. 

Judge White also found Hambright is entitled to qualified immunity because Howell did not identify clearly established U.S. Supreme Court or published Sixth Circuit precedent showing every reasonable officer would have known the conduct was unconstitutional. 

The court further dismissed Howell's federal and state malicious prosecution claims, finding probable cause supported the prosecution. Judge White pointed to the DNA evidence and Gaston's identification, which a state district judge relied on when binding Howell over for trial. 

"Since no reasonable jury could decide that (1) Hambright participated in the decision to prosecute Howell, or (2) insufficient probable cause existed to arrest Howell and charge him with armed robbery, Hambright did not violate the Fourth Amendment," the judge wrote. 

The court also said Howell could not show malice under Michigan law. 

"No reasonable jury could infer from the record that Hambright failed to disclose evidence to prosecutors out of malice towards Howell," Judge White wrote. 

The parties did not immediately respond to requests for comment Thursday.

Howell is represented by Wolfgang Mueller of Mueller Law Firm. 

Hambright is represented by Timothy S. Ferrand of Cummings McClorey Davis & Acho PLC.

The case is Howell v. Hambright, case number 2:23-cv-12202, in the U.S. District Court for the Eastern District of Michigan.

--Editing by Amy French.

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