Case Explained: 26a0229p.06

Court: United States Court of Appeals for the Sixth Circuit Filed: 2026-08-13 The Sixth Circuit affirmed the district court’s dismissal of Plaintiff Derek Antol’s Fourth Amendment claim regarding the validity of the search warrant and his Fourteenth Amendment substantive due process claim, but reversed the dismissal of his Fourth Amendment unreasonable seizure claim against Defendant Josephs and remanded for further proceedings. The court held that the search warrant affidavit contained sufficient probable cause to support a search for an illegal marijuana operation, even after excising alleged false statements or omissions regarding tax evasion and money laundering, thereby entitling the officers to qualified immunity on the unlawful search claim. Regarding the Fourteenth Amendment claim, the court ruled it was duplicative of the Fourth Amendment claim because the conduct occurred during a seizure of a free citizen, meaning the Fourth Amendment’s objective reasonableness standard governs rather than substantive due process. However, the court determined that Plaintiff plausibly alleged a violation of his Fourth Amendment right against unreasonable seizures when Defendant Josephs denied him access to his own restroom while detained, forcing him to urinate in his front yard. Applying the *Graham v. Connor* totality-of-the-circumstances test, the court found the seizure unreasonable because the severity of the crime did not justify such a restriction given Plaintiff’s compliance and lack of threat, and the denial was not necessary to prevent evidence destruction as officers had already allowed brief supervised access to the home. The court further concluded that this right was clearly established under an “obvious” standard, meaning any reasonable officer would have understood that denying a detained individual’s urgent request for restroom access while supervised violated constitutional protections against unreasonable seizures. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.