Kevin Lamb v. Scott Crofoot

NOT RECOMMENDED FOR PUBLICATION

File Name: 25a0530n.06

Case No. 25-1313

UNITED STATES COURT OF APPEALS

FOR THE SIXTH CIRCUIT

FILED

Nov 19, 2025

) KELLY L. STEPHENS, Clerk

KEVIN R. LAMB

)

Plaintiff-Appellant, )

) ON APPEAL FROM THE UNITED

v. )

STATES DISTRICT COURT FOR

)

) THE EASTERN DISTRICT OF

SCOTT CROFOOT and TOWNSHIP OF MICHIGAN

)

JONESFIELD,

)

Defendants-Appellees. ) OPINION

Before: THAPAR, READLER, and HERMANDORFER, Circuit Judges.

THAPAR, Circuit Judge. Kevin Lamb wanted to build a greenhouse in his front yard.

Unfortunately, that project violated local zoning ordinances. So inspector Scott Crofoot entered

Lamb’s property and put up a stop work order. Lamb believes Crofoot’s actions violated the

Constitution and Michigan law. They did not.

I.

A few years ago, Kevin Lamb began constructing a vegetable greenhouse in the front yard

of his house in Jonesfield Township, near the intersection of two roads. Scott Crofoot, an inspector

for the Township, received a complaint about the construction and determined that Lamb hadn’t

received a construction permit. So he drove to Lamb’s home and walked onto the property to

No. 25-1313, Lamb v. Crofoot

inspect the greenhouse. After entering, Crofoot met Lamb’s adult daughter and her boyfriend and

told them the construction needed to stop.

While Crofoot was waiting in his driveway, Lamb came out of his house and demanded

that Crofoot leave. Lamb told Crofoot to send him any concerns about the greenhouse in writing.

In response, Crofoot pulled out a business card and dropped it on the ground by Lamb. Crofoot

then returned to his car and drove partially onto Lamb’s yard. He wrote up a “stop work” order

and attempted to post it to the greenhouse, although the order fell to the ground. After that, Crofoot

drove away and called the police. Thereafter, he met with a police officer whose body camera

recorded their conversation. During the conversation, he told the police that Lamb had assaulted

him by “chest-butt[ing]” him, but Lamb denies that. R. 12, Pg. ID 98–99.

Four days later, Crofoot mailed a “Notice of Violation and Order” to Lamb, commanding

him to correct the alleged violations before reinspection in one month. Id., Pg. ID 99. The notice

identified multiple violations of the Township’s zoning ordinances, including that the greenhouse

was being built in the street’s right-of-way, an allegation which Lamb also denies. So Lamb

dismantled the greenhouse. Afterward, Lamb was arrested and charged with felony assault for

allegedly pushing Crofoot. The Saginaw County prosecutor’s office dismissed those charges but

re-issued them after Lamb brought this suit.

Based on these events, Lamb sued Crofoot and Jonesfield Township in the United States

District Court for the Eastern District of Michigan. He brought two section 1983 claims against

both Crofoot and Jonesfield Township, alleging violations of his Fourteenth and Fourth

Amendment rights. 42 U.S.C. § 1983. Lamb brought those claims against Crofoot in his

individual capacity, alleging that Crofoot violated those rights by entering his land and posting the

stop work order. And he brought the same claims against Jonesfield Township, alleging that

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No. 25-1313, Lamb v. Crofoot

Crofoot committed those violations under a policy or practice of the Township. Lamb also brought

a state-law trespass claim against both defendants and challenged the Township’s zoning

ordinance as violating the Fourth Amendment.

The district court granted defendants’ motion to dismiss for failure to state a claim. It

found that Lamb had failed to allege a protected property interest in building a greenhouse in

violation of municipal zoning requirements, so his Fourteenth Amendment claim failed. The

district court similarly rejected Lamb’s Fourth Amendment claim because Crofoot’s entry onto his

land to post a stop work order wasn’t a search or a seizure. And because there was no constitutional

violation, the court rejected Lamb’s claim against the Township. The court also threw out Lamb’s

challenge to the zoning ordinance. It found Lamb’s as-applied challenge failed because Crofoot’s

past actions were constitutional, and it held Lamb lacked standing to bring a facial challenge.

Finally, the court declined to exercise supplemental jurisdiction over Lamb’s state-law trespass

claims. And it dismissed Lamb’s complaint with prejudice.

We review a district court’s grant of a motion to dismiss de novo and can affirm on any

ground supported by the record. Gerboc v. ContextLogic, Inc., 867 F.3d 675, 678 (6th Cir. 2017).

At this stage, we accept Lamb’s well-pleaded factual allegations as true. Id.

II.

To succeed on his section 1983 claims, Lamb must show that Crofoot deprived him of

“rights, privileges, or immunities secured by the Constitution and laws” while acting under “color

of” state law. 42 U.S.C. § 1983. Because Crofoot is a municipal official, he enjoys qualified

immunity. See District of Columbia v. Wesby, 583 U.S. 48, 62 (2018). That means Lamb must

also clear a two-step test to obtain damages: First, he must show that Crofoot violated his rights.

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No. 25-1313, Lamb v. Crofoot

Id. at 62–63. Second, Lamb must show that precedent “clearly established” that Crofoot’s actions

violated the Constitution. Id. at 63.

Lamb’s claims fail at the first step. He argues his Fourteenth and Fourth Amendment rights

were violated. But Lamb didn’t have a property interest in building the greenhouse, so Crofoot

didn’t violate his Fourteenth Amendment rights by ordering him to stop work. And Crofoot’s

actions didn’t constitute a seizure, which is the only Fourth Amendment argument Lamb raises on

appeal.

A.

First, Lamb argues that Crofoot’s stop work order violated his Fourteenth Amendment

procedural due process rights. To succeed on a procedural due process claim, a plaintiff must

show that (1) he has a life, liberty, or property interest protected by the Fourteenth Amendment,

(2) he was deprived of that interest, and (3) he was not afforded sufficient process before the

deprivation. Hahn v. Star Bank, 190 F.3d 708, 716 (6th Cir. 1999). Those first two steps are

critical: Lamb must point to some lost property interest before we consider the adequacy of the

process he received.

So what property was Lamb deprived of? He doesn’t identify any tangible property—like

Crofoot hauling away his car. Instead, Lamb contends that he had a right to build a greenhouse

on his land, and Crofoot deprived him of this interest when he posted the stop work order.

But Lamb has no property interest in building a greenhouse in his yard. To have a property

interest, a plaintiff must possess a “legitimate claim of entitlement to it,” not just “a unilateral

expectation.” Bd. of Regents of State Colls. v. Roth, 408 U.S. 564, 577 (1972). That entitlement

must arise from an “independent source such as state law.” Id. True, state law can’t abrogate

traditional interests in property. Cf. Tyler v. Hennepin County, 143 S. Ct. 1369, 1375 (2023). But

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No. 25-1313, Lamb v. Crofoot

a valid zoning ordinance can nevertheless inform the scope of an individual’s property interest in

a particular use of land. See White Oak Prop. Dev., LLC v. Washington Township, 606 F.3d 842,

853 (6th Cir. 2010). Lamb doesn’t argue that the zoning ordinance at issue invades any traditional

property interest. The parties instead focus on whether the ordinance is valid under Michigan law

and thus a relevant restriction on Lamb’s use of the property in the first place.

Here, the Township’s ordinance is clear. Section 306(1)(a) prohibits constructing

“accessory building[s]” in “front yard[s].” Jonesfield Twp., Mich., Zoning Ordinance, § 306(1)(a).

Greenhouses count as accessory buildings under the ordinance. Id. § 202(4). And the ordinance

defines “[f]ront yard” as “[a] yard extending across the full width of the lot.” Id. § 202(192)(b).

Lamb tried to construct an accessory building (his greenhouse) in a corner of a yard that extends

across the full width of the lot (his front yard). That construction thus violated the Township’s

ordinance, and Lamb had no property interest in using his land to construct a greenhouse.

Lamb seems to acknowledge this reading of the Township’s ordinance. But he claims that

Michigan’s Right to Farm Act (RTFA) preempts the local zoning ordinance governing

greenhouses. Mich. Comp. Laws §§ 286.473(1), 286.474(6). He is wrong. It’s true that the RTFA

supersedes any local zoning ordinance “to the extent that it would prohibit conduct protected by

the” Act. Charter Township of Shelby v. Papesh, 704 N.W.2d 92, 103 (Mich. Ct. App. 2005);

accord Township of Fraser v. Haney, No. 368834, 2025 Mich. App. LEXIS 6358, *7 (Mich. Ct.

App. July 9, 2025). But what protection does the RTFA give? As relevant here, it says only that

a “farm or farm operation shall not be found to be a public or private nuisance if” the

activities comply with generally accepted farming standards. Mich. Comp. Laws §§ 286.473(1),

286.474(6). As the Michigan Supreme Court has made clear, this protection from nuisance

suits doesn’t exempt Lamb from zoning ordinances governing the location of greenhouses.

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No. 25-1313, Lamb v. Crofoot

Papadelis v. City of Troy, 733 N.W.2d 397, 398 (Mich. 2007) (“[N]o provisions of the RTFA or

any published generally accepted agricultural and management practice address the . . . location

of buildings used for greenhouse[s].”). Generally accepted farming standards still don’t cover

greenhouse locations today. Michigan Department of Agriculture and Rural Development,

GAAMPs, https://perma.cc/6FL2-XT4H (last visited Oct. 24, 2025). And since the RTFA doesn’t

preempt the Township’s ordinances, those ordinances govern whether Lamb can build a

greenhouse in his front yard. So Lamb was not deprived of a property interest, and there was no

Fourteenth Amendment violation.

B.

Lamb also argues that Crofoot violated his Fourth Amendment rights. He admits that

Crofoot’s original entry onto his property was a permissible “knock and talk.” See Smith v. City

of Wyoming, 821 F.3d 697, 713 (6th Cir. 2016). But, in Lamb’s telling, Crofoot violated the Fourth

Amendment by driving back onto Lamb’s property without a warrant and attempting to post the

stop work order on the greenhouse after Lamb told him to leave. Lamb argues this was an

unreasonable seizure of his “private property being used to build his greenhouse” because it

interfered with his “free use of private property.” Appellant Br. at 30.1

1

Defendants ignore this argument entirely. Crofoot contends that his actions couldn’t have constituted a search under

the Fourth Amendment because he merely conducted an administrative inspection, and Lamb had no reasonable

expectation of privacy in the greenhouse. But searches and seizures are distinct ways of violating the Fourth

Amendment, so this argument doesn’t respond to Lamb’s seizure claim. See United States v. Jacobsen, 466 U.S. 109,

113 (1984). Although that means Crofoot forfeited this argument, we still reach this question in the interest of judicial

economy. See Elzy v. United States, 205 F.3d 882, 886 (6th Cir. 2000). If Lamb’s claims survive a motion to dismiss

because of Crofoot’s forfeiture, Crofoot would simply move for summary judgment on the seizure claim. And because

Lamb’s seizure argument fails as a matter of law, the outcome would be the same at summary judgment as at a motion

to dismiss. What’s more, the district court already rejected Lamb’s seizure argument employing reasoning similar to

our own. So we save judicial resources by resolving this argument now. Cf. Lexicon, Inc. v. Safeco Ins. Co. of Am.,

436 F.3d 662, 670 n.6 (6th Cir. 2006).

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No. 25-1313, Lamb v. Crofoot

The Fourth Amendment protects citizens’ “persons, houses, papers, and effects” from

“unreasonable searches and seizures.” U.S. Const. amend. IV. Seizures of property occur “when

there is some meaningful interference with an individual’s possessory interests in that property.”

United States v. Jacobsen, 466 U.S. 109, 113 (1984). That usually means the official must “tak[e]

possession” of the property. F.P. Dev., LLC v. Charter Township of Canton, 16 F.4th 198, 208

(6th Cir. 2021) (quoting Torres v. Madrid, 592 U.S. 306, 312 (2021)). And if an official takes

possession, the resulting seizure is generally unreasonable if the official doesn’t have a warrant.

United States v. Place, 462 U.S. 696, 701 (1983).

Under this rule, Crofoot didn’t seize Lamb’s property. There are two ways to construe

Lamb’s argument regarding what Crofoot allegedly seized. Both fail. First, his argument could

suggest that Crofoot seized his land by stopping him from building a greenhouse. But the Fourth

Amendment doesn’t include land in its text—“persons, houses, [or] papers.” U.S. Const. amend.

IV. And this court has concluded that it is not an “effect” either. F.P. Dev., 16 F.4th at 208 (citing

Oliver v. United States, 466 U.S. 170, 177 n.7 (1984) (“The Framers would have understood the

term ‘effects’ to be limited to personal, rather than real, property.”)). Thus, the Fourth Amendment

doesn’t protect land from seizures.2

Even if Lamb instead contends that Crofoot seized the greenhouse, his argument would

still fail. While the stop work order apprised Lamb that the construction violated the Township’s

ordinances, it didn’t meaningfully interfere with his possession of his property. That’s because

Lamb kept possession of the partially built greenhouse even after Crofoot posted the stop work

2

That is not to say the government can take one’s land without consequence. Usually, that’s considered a taking. But

Lamb doesn’t argue that Crofoot’s conduct amounted to a taking—regulatory or otherwise. So we need not decide

that question, and this analysis doesn’t implicate whether those actions or the Township’s policies would support a

valid Fifth Amendment claim.

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No. 25-1313, Lamb v. Crofoot

order—the greenhouse remained on his front yard. And Lamb retained possession of the material

used to construct the greenhouse after taking it apart. In short, Crofoot never seized the greenhouse

or any part of it.

This finding is consistent with our holding in F.P. Development. 16 F.4th at 208. There,

a county official posted a stop work order on the plaintiff company’s land advising it not to remove

certain trees in violation of local ordinances. Id. at 202. The company sued and argued that the

township’s ordinance authorized an unreasonable seizure. Id. at 201, 208. We disagreed. The

“standing trees” that remained on the plaintiff’s land were real property not subject to the Fourth

Amendment. Id. at 208. And the plaintiff retained full control over the trees it removed from its

property, so the county had not seized them. Id. The same is true here.

In response, Lamb points to Soldal v. Cook County, where the Supreme Court found that

officials had committed a seizure after they tore a mobile home from its foundations and towed it

away. 506 U.S. 56, 58 (1992). But there was a seizure in Soldal because the government took the

property away. Thus, the property owner lost possession of his mobile home, whereas Lamb kept

possession of his greenhouse. Far from towing it away, Crofoot left the greenhouse where he

found it, and Lamb himself later dismantled it.

Because Lamb only argues on appeal that Crofoot seized his property, we need not consider

whether his intrusion constituted an unlawful search. And because Lamb retained full possession

of the greenhouse, Crofoot didn’t commit a seizure in violation of Lamb’s Fourth Amendment

rights.

C.

Lamb brings his Fourth and Fourteenth Amendment claims against Jonesfield Township

in addition to Crofoot. But to make out such a claim against a municipality like the Township, a

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No. 25-1313, Lamb v. Crofoot

plaintiff must allege that officials violated his rights pursuant to a municipal policy or custom. See

Monell v. Dep’t of Soc. Servs., 436 U.S. 658, 694 (1978). As discussed above, Lamb hasn’t shown

that his Fourteenth or Fourth Amendment rights were ever violated. So regardless of whether a

policy or custom exists, these claims against the Township fail.

III.

A.

Hoping to stop inspectors from coming onto his land in the future, Lamb also brings a pre-

enforcement challenge to section 901(1)(D) of the Jonesfield Township Zoning Ordinance. This

ordinance authorizes officials “to make inspections of any building or parcel as necessary to

enforce this Ordinance.” Jonesfield Twp., Mich., Zoning Ordinance § 901(1)(D). Because that

language doesn’t include any warrant requirement or lay out an administrative procedure to

challenge inspections, Lamb argues that it authorizes unlawful inspections. And Lamb believes

he has standing to bring both a facial and an as-applied challenge to the ordinance because Crofoot

threatened to inspect his property without a warrant. Specifically, Lamb points to a letter he

received from Crofoot saying that he would return for a reinspection on or around November 28,

2023.

But Lamb lacks standing to challenge section 901(1)(D). To have standing a plaintiff must

show three things: (1) an injury-in-fact that is (2) traceable to the defendant’s actions and (3) likely

to be redressed by a favorable court decision. See Lujan v. Defs. of Wildlife, 504 U.S. 555, 560

(1992). And to establish an injury-in-fact, not just any alleged harm will do. The injury must be

“concrete, particularized, and actual or imminent.” TransUnion LLC v. Ramirez, 594 U.S. 413,

423 (2021). These standing requirements ensure the plaintiff has a personal stake in the outcome

of the case, and they apply regardless of whether Lamb’s challenge is facial or as-applied. See id.;

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No. 25-1313, Lamb v. Crofoot

Miller v. City of Wickliffe, 852 F.3d 497, 502 (6th Cir. 2017). Lamb fails at the first prong of

Lujan’s test because his claimed harm is neither actual nor imminent.

Lamb alleges no “actual” harm that allows a pre-enforcement suit. In the pre-enforcement

context, only ongoing harms count as actual. See Clark v. Stone, 998 F.3d 287, 294 (6th Cir.

2021). Past harms that are not ongoing do not qualify. See id.; City of Los Angeles v. Lyons, 461

U.S. 95, 111 (1983). So even if Lamb alleged that Crofoot had inspected him under section

901(1)(D) in the past, that wouldn’t be an actual harm giving Lamb standing to bring a pre-

enforcement suit. And Lamb hasn’t pointed to any ongoing harm caused by that provision. He

claims that he has been “chilled” from rebuilding a greenhouse because of his fear of being

inspected without a warrant. That theory fails several times over.

To start, Lamb’s allegations are nowhere in his complaint. He waited until his opening

brief to allege any intention to rebuild. And he waited until his reply brief to claim he has been

“chilled” by fear of reinspection. In this posture, we “must focus only on the allegations in the

pleadings.” Bates v. Green Farms Condo. Ass’n, 958 F.3d 470, 483 (6th Cir. 2020). So we cannot

rule for Lamb using his “new allegations (or evidence) not contained in the complaint.” Id.

That problem aside, Lamb’s “chilling” theory also lacks causation and redressability. It’s

not plausible that Lamb is declining to build a greenhouse out of fear he will be subject to a

warrantless inspection. After all, he had to take apart his greenhouse because it violated the

Township’s zoning ordinance. So an allegedly unlawful inspection under section 901(1)(D) isn’t

causing him not to construct. And it’s hard to see how any chilling effect would be redressable by

a ruling on section 901(1)(D)’s scope, since Lamb’s zoning-rule problem would remain.

Regardless of these issues, we haven’t recognized subjective “chill” as an injury-in-fact in

the Fourth Amendment context. Cf. Clapper v. Amnesty Int’l USA, 568 U.S. 398, 418 (2013)

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No. 25-1313, Lamb v. Crofoot

(finding that “self-inflicted injuries” don’t support standing). Lamb’s un-pled theory gives no

reason to chart a different path.

Lamb has also failed to show an “imminent” harm. The imminence requirement demands

at least a “substantial risk” that the harm will occur. Susan B. Anthony List v. Driehaus, 573 U.S.

149, 158 (2014) (quoting Clapper, 568 U.S. at 414 n.5). There is no substantial risk that Lamb

will be subject to an unlawful warrantless search. While Crofoot’s letter threatened to conduct an

inspection on or around November 28, 2023, that inspection never happened. And now there isn’t

even any greenhouse to inspect—Lamb dismantled it. Lamb doesn’t identify any other structures

on his property that Crofoot, or anyone else in the Township, has threatened to inspect.

Even if we considered Lamb’s late-stated claim that he wants to “promptly rebuild” the

greenhouse and worries about an unlawful inspection, he runs into additional problems. Reply Br.

at 11. Injuries that are “highly speculative” and depend on “a highly attenuated chain of

possibilities” are not imminent. Clapper, 568 U.S. at 410. Lamb’s injury requires a speculative

chain of causation: Lamb would need to rebuild the greenhouse, Crofoot would need to decide to

inspect it again, that inspection would have to amount to a “search” under the Fourth Amendment,

and it would need to be conducted without either a chance for pre-compliance review or a warrant.

Cf. id. That first step is itself highly speculative—Lamb provides no concrete plans beyond a

desire to “promptly” rebuild.

The same goes for Lamb’s concern that Crofoot would then inspect his greenhouse in

violation of the Fourth Amendment. For one, a search may never occur. Lamb’s greenhouse is in

his front yard. Supra page 5. While Crofoot’s letter said he would reinspect the property, that

could be done via a quick visual inspection from the public road to see whether the greenhouse is

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No. 25-1313, Lamb v. Crofoot

still standing. See Allinder v. State of Ohio, 808 F.2d 1180, 1184–85 (6th Cir. 1987). That would

not be a search. Id.

But even if a search were to occur, we don’t know whether it would violate the Fourth

Amendment. Municipalities can comply with the Fourth Amendment by setting out a valid

administrative search regime or by procuring a warrant. See Benjamin v. Stemple, 915 F.3d 1066,

1069 (6th Cir. 2019) (citing City of Los Angeles v. Patel, 576 U.S. 409, 420 (2015)). Jonesfield

Township’s ordinances might constitute a valid administrative search regime. For a search regime

to be valid, municipalities must provide “precompliance review before a neutral decisionmaker.”

Patel, 576 U.S. at 420. Jonesfield’s ordinances seem to provide that review by giving “any

aggrieved person” the chance to appeal any decision or action by the Zoning Administrator.

Jonesfield Twp., Mich., Zoning Ordinance § 903(2)(A). In this case, for example, Lamb could

have appealed Crofoot’s threatened re-inspection to the Zoning Board of Appeals because the

threatened inspection likely qualified as an appealable “Zoning Administrator’s Decision.”

Jonesfield Twp., Mich., Zoning Ordinance § 909 (Zoning Ordinance Actions Table). That would

have given Lamb a public hearing and thus the required “precompliance review.” To be sure, it’s

unclear whether Jonesfield regularly sends pre-inspection notices like the one Lamb received. But

that just underscores that Lamb’s present claim is too speculative.

Lamb’s worry that Crofoot would return without a warrant is also speculative. While

section 901(1)(D) doesn’t expressly require a warrant to conduct an inspection, it doesn’t forbid

getting one either. Instead, the provision just gives inspectors the authority to conduct inspections,

and that authority is still constrained by the Fourth Amendment. Inspectors are presumed to follow

the law, and Lamb can’t point to a history of constitutional violations because Crofoot didn’t

violate Lamb’s Fourth Amendment rights on his previous inspection. See O’Shea v. Littleton, 414

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No. 25-1313, Lamb v. Crofoot

U.S. 488, 497 (1974); Driehaus, 573 U.S. at 165. So it’s speculative that a Township inspector

would violate Lamb’s Fourth Amendment rights under section 901(1)(D), even if Lamb does

rebuild the greenhouse.

Together, this chain of uncertain events means there is no “substantial risk” that Lamb will

experience a Fourth Amendment violation. See Driehaus, 573 U.S. at 158 (quoting Clapper, 568

U.S. at 414 n.5). Thus, he has not shown an imminent injury. And because Lamb has not

established an actual injury either, he lacks standing to challenge the Township’s ordinance. The

district court correctly dismissed his claims.3

B.

Lamb further argues that the district court erred by dismissing his challenges to section

901(1)(D) with prejudice. He is correct. A dismissal with prejudice acts as a ruling on the merits,

and a federal court cannot decide the merits of a claim when it lacks jurisdiction. See Jackson v.

City of Cleveland, 925 F.3d 793, 809 (6th Cir. 2019). Because Lamb lacked standing to challenge

that provision, the district court didn’t have jurisdiction over that claim.

Accordingly, the district court should have dismissed Lamb’s challenges to section

901(1)(D) without prejudice. And if Lamb can establish standing, he can bring his facial and as-

applied claims again.

IV.

Similarly, the district court declined to exercise supplemental jurisdiction over Lamb’s

state-law trespass claim. Thus, as with the section 901(1)(D) claim, this claim must be dismissed

3

The district court rejected Lamb’s as-applied challenge because he did not allege a past or present injury. But “past,

present, or future” injury suffices for actual harm for an as-applied challenge. Vonderhaar v. Village of Evendale, 906

F.3d 397, 400–01 (6th Cir. 2018) (emphasis added). The district court should have analyzed the absence of future

injury when dismissing Lamb’s as-applied challenge, not just his facial challenge.

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No. 25-1313, Lamb v. Crofoot

without prejudice. See Vandiver v. Hardin Cnty. Bd. of Educ., 925 F.2d 927, 935 (6th Cir. 1991).

So Lamb remains free to litigate his trespass claim in state court.

V.

Finally, Lamb argues that the district court erred by declining to consider body camera

footage of Crofoot’s statements to the police after Lamb allegedly assaulted him. He contends that

those statements undermine Crofoot’s justification for entering his property and issuing the stop

work order. But district courts should not consider video evidence at the motion-to-dismiss stage

unless that evidence “blatantly contradict[s]” the complaint. Bell v. City of Southfield, 37 F.4th

362, 364 (6th Cir. 2022) (quoting Scott v. Harris, 550 U.S. 372, 380 (2007)). Far from

contradicting his complaint, Lamb contends that the video supports his allegations. So the district

court correctly declined to consider the body camera footage.

And in any event, the district court accepted as true Lamb’s allegations that Crofoot had

lied to police about the assault and that the greenhouse didn’t interfere with a right-of-way.

Considering the video evidence wouldn’t have affected the court’s ruling.

* * *

Lamb can legally use his front yard for many different things. That includes landscaping,

barbecues, and frisbee. But the Township’s ordinance says he can’t use it for greenhouse-building.

Lamb’s challenges to that restriction fail, and Crofoot’s actions didn’t violate Lamb’s

constitutional rights. We affirm in part, reverse in part, and remand to the district court with

instructions to dismiss Lamb’s state-law claim and his challenge to section 901(1)(D) of the

ordinance without prejudice.

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