GRAND RAPIDS, MI, October 17, 2025 — The U.S. Court of Appeals for the Sixth Circuit has affirmed the dismissal of a lawsuit filed by former Michigan Department of Corrections officer Charles Bozzo, who alleged that his firing in 2019 violated his constitutional right to due process.
Bozzo sued MDOC Director Heidi Washington and Discipline Coordinator Jennifer Nanasy under 42 U.S.C. § 1983, claiming that the department relied on false allegations and an unfair arbitration process to terminate him following workplace misconduct complaints. The district court dismissed the suit as time-barred and for failure to state a claim.
According to the ruling, Bozzo was terminated on July 31, 2019, after a coworker accused him of making harassing remarks. He pursued arbitration through his union, which upheld his dismissal in March 2021. Bozzo later filed his federal complaint in June 2024, more than three years after his claim accrued. The Sixth Circuit found that Michigan’s three-year statute of limitations for personal injury actions applied and that Bozzo’s case was filed too late.
The court also rejected Bozzo’s arguments for equitable tolling and ruled that his due process claim failed on the merits. Judges held that Bozzo received notice of the charges, an opportunity to respond before his termination, and a post-termination arbitration hearing before a neutral decisionmaker—meeting constitutional requirements for due process.
The appellate court affirmed the judgment of the U.S. District Court for the Western District of Michigan.
