JOSHUA STEEB v. MIKE EHART, in his individual and official capacities; CITY OF BATTLE CREEK, MICHIGAN, jointly and severally - Articles

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JOSHUA STEEB v. MIKE EHART, in his individual and official capacities; CITY OF BATTLE CREEK, MICHIGAN, jointly and severally

Posted by: Julia Wilburn on Jan 28, 2026

Head Comment: CLAY dissenting

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ARGUED: Jeffrey L. Herron, HERRON LAW FIRM, Detroit, Michigan, for Appellant.

Attorneys 2: ARGUED: Patrick J. Batterson, CITY OF BATTLE CREEK, Battle Creek, Michigan, for Appellees.

Attorneys 3: ON BRIEF: Jeffrey L. Herron, HERRON LAW FIRM, Detroit, Michigan, for Appellant.

Attorneys 4: ON BRIEF: Patrick J. Batterson, CITY OF BATTLE CREEK, Battle Creek, Michigan, for Appellees.

Judge(s): CLAY, GILMAN, and BLOOMEKATZ, Circuit Judges

Court Appealed: United States District Court for the Western District of Michigan at Grand Rapids

Joshua Steeb rescued his friend from a dog attack, but then the dog turned on him, mauling him and causing permanent injuries. To redress these injuries, he brought a claim against Battle Creek animal control officer Mike Ehart under the “state-created-danger” theory of substantive due process, alleging that Ehart created the dangerous circumstances that resulted in the dog attack. He also sued the City of Battle Creek for failure to adequately train and equip Officer Ehart. The district court dismissed both of Steeb’s claims for failure to successfully plead a constitutional violation. We agree and affirm.

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