Summary
The Sixth Circuit affirmed dismissal of an estate’s federal equal-protection claims arising from the murder of Linda Henry by a neighbor. The court held that the estate lacked prudential standing because the alleged discriminatory denial of protective services affected other women, not Henry personally, and the estate did not establish third-party standing. The court also held that the estate waived any challenge to the district court’s refusal to exercise supplemental jurisdiction over its state-law claims.
Topics
Practice areas
Questions Presented
- Whether the Estate had standing to assert federal equal-protection claims based on allegedly discriminatory treatment experienced by other women rather than by Linda Henry.
- Whether the Estate could invoke the limited exception permitting third-party standing to assert the equal-protection rights of other women.
- Whether the district court's refusal to exercise supplemental jurisdiction over the Michigan-law claim was waived on appeal because the Estate did not challenge that ruling.
Holdings
- The Estate lacked standing to assert equal-protection claims based on discriminatory treatment that Henry did not personally experience. Equal-protection rights belong to the person who was denied equal protection, and Henry did not allege that the Sheriff's Office ignored, minimized, or failed to respond to a report made by her.
- The Estate could not invoke the limited exception for third-party standing because it failed to establish a close relationship with the women whose rights it sought to assert and failed to identify any hindrance preventing those women from protecting their own interests.
- The Estate waived any challenge to the district court's refusal to exercise supplemental jurisdiction over its Michigan-law claims by failing to raise that argument in its appellate brief.
Key quotations
“To state a claim under the Equal Protection Clause, a § 1983 plaintiff must allege that a state actor intentionally discriminated against the plaintiff because of membership in a protected class.” (p. 6)
“A failure to satisfy this prudential rule, moreover, dooms a plaintiff’s claims, even when the plaintiff has alleged injury sufficient to meet the ‘case or controversy’ requirement.” (p. 7)
“The Estate’s failure to demonstrate third-party standing thus forecloses its equal-protection claims.” (p. 8)
Factual background
Linda Henry was murdered by her neighbor Jeffrey Stratton after the Benzie County Sheriff's Office received multiple reports that Stratton threatened or endangered women and girls. The Estate alleged that the Sheriff's Office had a policy or practice of providing inferior protective services in response to threats against women compared with threats against men. Henry herself did not report the relevant threats to the Sheriff's Office before the murder; when her son called 911 on the day of the murder, numerous officers responded and immediately arrested Stratton.
Procedural history
The Estate filed suit in January 2025 against Benzie County and four sheriff's deputies, asserting federal equal-protection claims under § 1983 and a claim under Michigan's Elliott-Larsen Civil Rights Act. The United States District Court for the Western District of Michigan dismissed the complaint in its entirety in July 2025, concluding that the federal claims failed for lack of standing and failure to state a claim and declining supplemental jurisdiction over the state claim. The Sixth Circuit affirmed.