James Lee Saltmarshall Case: Autopsy, Dropped Charges, and Civil Suit

The James Lee Saltmarshall case began on April 20, 2017, when the 22-year-old Michigan father was arrested at an Inkster motel and charged days later with felony murder, first-degree child abuse, and first-degree criminal sexual conduct in the death of his eight-month-old daughter, Janiyah. Roughly two months later, the Wayne County Medical Examiner ruled the death an accidental asphyxiation, contradicting the hospital doctors whose reports of skull fractures, shaken baby syndrome, and sexual assault had driven the prosecution. Prosecutors dropped all charges on June 29, 2017. Saltmarshall then sued the police, doctors, and hospitals in federal court, and the courts dismissed every claim.¹

How Janiyah Saltmarshall Died

Saltmarshall called 911 on the afternoon of April 20, 2017, from the Alpine Motel on Michigan Avenue in Inkster after finding his daughter unresponsive. He told authorities he and Janiyah had been sleeping together on an adult-sized bed and that she was not breathing when he woke. The child’s mother, Zuleika Moreno, had left for work earlier that morning.¹

Paramedics found the infant in cardiac arrest with respiratory failure. She was taken to Garden City Hospital and then to Children’s Hospital of Michigan. After two confirmatory examinations, Janiyah was declared brain dead at 7:36 a.m. on April 23, 2017.²

The Medical Findings That Led to the Arrest

Three physicians reported findings consistent with severe abuse, and those reports drove the arrest and charges.

At Garden City Hospital, emergency room physician Dr. Shawna Wright reported what she described as a large, bleeding rectal tear along with a bloody nose and prolonged loss of pulse. She told Inkster Police Lieutenant Jeffrey Smith that the injuries were “consistent with suspected child abuse” and could have been caused by something inserted into the infant’s rectum. Wright and another doctor filed a mandatory child abuse report.²

After Janiyah was transferred to Children’s Hospital of Michigan, pediatric surgeon Dr. Scott Langenberg sent a text message to Inkster Police Lieutenant Jeffrey Twardzik that became central to the case: “Baby has skull fractures, brain swelling on CT … Lung bruising, anterior anal laceration. We have some other studies pending. This is non-accidental trauma. The perpetrator murdered this child.”³

Much of that text was wrong. Langenberg later admitted he had not reviewed any official imaging reports before sending it. A resident had misidentified normal suture lines in the infant’s skull as fractures, and the final radiology reading confirmed no skull fractures existed. Langenberg used the word “murdered” while the child was still alive, and later testified in a deposition that he meant it in a “medical sense” to indicate lethal injuries. The court noted that “murdered” has no recognized medical meaning. Langenberg never informed police that his initial claims about skull fractures were inaccurate.³⁴

A third physician, pediatric critical care specialist Dr. Christian Bauerfeld, told Detective Jonathan Munson on April 21 that Janiyah had bilateral retinal hemorrhaging “indicative of shaken baby syndrome” and an anal laceration, calling the injuries “highly suspicious for nonaccidental trauma.”²

Lieutenant Smith arrested Saltmarshall on April 20 for criminal sexual conduct based on his conversation with Dr. Wright. On April 24, Wayne County prosecutor Jennifer Tink, after consulting supervisor Karen Goldfarb of the Child Abuse Unit, filed a felony complaint charging Saltmarshall with felony murder, first-degree child abuse, and first-degree criminal sexual conduct. He pleaded not guilty at arraignment that same day, and bond was set at $2 million.²

How the Autopsy Undid the Case

On the same day Saltmarshall was arraigned, Wayne County Medical Examiner Dr. Francisco Diaz performed the autopsy. He texted prosecutor Goldfarb that afternoon: “What we saw today doesn’t correlate with the vast clinical findings. We dissected the spine and eyes … But there were no major findings in terms of brain bleed and so on.”²

The Sixth Circuit later described what the autopsy actually showed. The “seemingly large rectal tear” that had alarmed emergency room doctors was a “minute fissure” likely caused by constipation. The suspected skull fracture was a “small laceration” with no clinical signs of shaken baby syndrome. The medical examiner concluded the death was accidental asphyxiation that occurred while Saltmarshall held the infant during sleep.⁵

Tink testified that once she learned the autopsy did not match the clinical reports, she immediately requested a personal bond with a GPS tether and told Saltmarshall’s attorney the state no longer wanted him held. On April 27, a court lowered the bond and he was released after eight days in jail. The Wayne County Medical Examiner issued a formal report on June 16, 2017, confirming the cause of death as asphyxia and the manner as accidental. Prosecutors moved to dismiss, and Judge Sabrina Johnson of Inkster District Court dismissed all charges without prejudice on June 29, 2017.²⁶

What Saltmarshall Said After His Release

His defense attorney, Lillian Diallo, was pointed in her criticism. “There was no evidence of sexual assault; there was no evidence of a skull fracture; there was no evidence of shaken baby syndrome; there was no evidence at all behind the charges,” she told reporters. “They should have never brought charges; never, ever, ever.”⁷

Diallo said the widely reported charges had labeled Saltmarshall a child rapist and murderer online, and that the dismissal would be treated as a footnote. She described him as deeply grieving, unable to attend his daughter’s funeral while jailed, and unaware of where Janiyah was buried at the time of his release.⁸

Janiyah’s mother, Zuleika Moreno, was on probation for third-degree child abuse at the time of the death and had previously lost custody of six children, according to Saltmarshall’s mother, Aisha Saltmarshall. Inkster police said Moreno did not have legal custody of Janiyah, and Child Protective Services had removed the infant from the grandmother’s care days earlier, on April 17.⁹

The Federal Civil Rights Lawsuit

Saltmarshall sued in the U.S. District Court for the Eastern District of Michigan (Case No. 18-10887). The suit named the City of Inkster, Lieutenants Smith and Twardzik, and Detective Munson; Prime Healthcare Services–Garden City and Dr. Wright; and VHS Children’s Hospital of Michigan, Dr. Langenberg, and Dr. Bauerfeld. He raised federal civil rights claims under 42 U.S.C. § 1983 along with state law claims for false arrest, false imprisonment, malicious prosecution, and defamation, and alleged the defendants conspired to deprive him of his rights on the basis of his race.²

Why the Claims Against the Police Failed

The district court granted summary judgment to all Inkster police defendants, finding “no reasonable jury could find that the police proceeded without probable cause or that the officers acted in bad faith.” The officers had relied on the medical opinions from the treating physicians, which at the time gave them sufficient grounds to arrest and investigate.²

In October 2020, the Sixth Circuit affirmed. The court held that the totality of circumstances known to officers, especially the emergency room doctor’s report of injuries inconsistent with Saltmarshall’s account, supported probable cause. The officers were entitled to qualified immunity, and there was no evidence they had given prosecutors reckless or false information. That the medical information later proved wrong did not make the officers’ reliance on it unreasonable at the time.⁵

Why the Claims Against the Doctors Failed

The federal Section 1983 claims against the medical defendants were dismissed because the court found insufficient facts to treat the doctors as “state actors” who could be sued under the federal civil rights statute. Some state law claims were dismissed under Michigan’s Child Protection Law, which shields medical professionals who report suspected child abuse in good faith.²

One state-law defamation claim against Dr. Langenberg and Children’s Hospital initially survived. The court found a jury could question whether Langenberg acted in good faith, given that he had “falsely asserted that the infant had skull fractures when he had not even seen any imaging studies,” labeled the situation a “murder” before the child died, and “took an active role in encouraging prosecution, despite his lack of accurate evidence.”⁴

On reconsideration, the court reversed itself. Relying on the Michigan Court of Appeals’ decision in Eddington v. Torrez (2015), which reaffirmed a Michigan Supreme Court precedent from Shinglemeyer v. Wright (1900), the court ruled that statements made to police officers about suspected criminal activity are protected by an absolute privilege under Michigan common law. That privilege applies regardless of the speaker’s intent or the accuracy of the information. On August 22, 2019, the court granted summary judgment for the remaining defendants and dismissed the amended complaint with prejudice.³¹⁰

The Eddington court noted that the privilege applies even to reports made maliciously, though Michigan’s separate criminal statutes against lying to police or making intentionally false reports remain available where bad faith can be shown. Under Michigan law, medical professionals are required to report suspected child abuse, and knowingly failing to do so carries criminal penalties and civil liability, while intentionally making a false report is itself a crime, punishable as a felony where the alleged abuse would be a felony.¹¹

Between the good-faith reporting shield, the state-actor requirement for federal civil rights claims, and the absolute privilege for statements to police, Saltmarshall walked out of jail cleared of the criminal charges but was left with no successful legal claim against the doctors, hospitals, or officers whose actions had put him there.

1
ClickOnDetroit. Case Dismissed Against Man Charged With Murder, Sexual Assault of 8-Month-Old in Inkster
2
U.S. District Court, Eastern District of Michigan. Opinion and Order on Motions for Summary Judgment, Case No. 18-10887
3
Findlaw. Saltmarshall v. VHS Children’s Hospital of Michigan, Inc.
4
Vlex. Saltmarshall v. VHS Children’s Hospital of Michigan, Inc.
5
U.S. Court of Appeals, Sixth Circuit. James Saltmarshall v. Prime Healthcare Servs., No. 19-1898
6
WXYZ Detroit. All Charges Dropped Against Inkster Father in Death of 8-Month-Old Girl
7
MLive. Dad’s Life Ruined by Claim He Raped, Killed Infant Daughter
8
Fox 5 DC. Tests Found Erroneous in Case Against Man Accused of Raping, Killing Infant Daughter
9
WXYZ Detroit. Mother of 8-Month-Old Allegedly Killed by Father Has History of Child Abuse
10
Michigan Court of Appeals. Eddington v. Torrez, 311 Mich. App. 198
11
Michigan Legislature. MCL 722.633, Child Protection Law