Justia U.S. 6th Circuit Court of Appeals Opinion Summaries

An employee at a construction company alleged that he faced repeated harassment at work after revealing that he was bisexual. According to his account, coworkers and a supervisor directed homophobic slurs and derogatory comments at him over several months. The employee reported the harassment to a manager on two occasions, initially without naming the harassers, and later with more details. Eventually, after a particularly hostile exchange, he formally complained to the company’s human resources department, which initiated an investigation. The HR manager interviewed the employee and nine other workers, none of whom corroborated his claims. Nonetheless, the company issued a written warning to the supervisor for inappropriate language, required all employees to review the antidiscrimination policy, and allowed the employee to transfer worksites and take medical leave.After the employee took extended medical leave, the company offered him several alternative work assignments, which he either declined or raised objections to. Ultimately, the company considered his refusals as a voluntary resignation and terminated his employment. The employee sued, alleging a hostile work environment and retaliation under Title VII and Michigan law.The United States District Court for the Eastern District of Michigan granted summary judgment to the employer on both claims. It found the company’s actions in response to the harassment allegations were prompt and appropriate, and that the employee failed to show that the termination was pretext for retaliation. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The appellate court held that the employer was not liable for coworker harassment because it took reasonable steps to investigate and address the allegations, and that the employee did not present sufficient evidence of pretext regarding his termination. View "Hamm v. Pullman SST, Inc." on Justia Law

A woman was murdered by her neighbor, who had a documented history of violence and mental illness. Over the two years preceding her death, the Sheriff’s Office in the relevant county received multiple reports about the neighbor’s threatening behavior, particularly toward women, but allegedly failed to act appropriately. The decedent’s estate claimed that the Sheriff’s Office systematically provided inferior protective services in response to threats against women compared to men, citing examples involving both the decedent and other women who reported threats. The estate asserted claims under the Equal Protection Clause and Michigan’s Elliott-Larsen Civil Rights Act.The United States District Court for the Western District of Michigan dismissed the federal claims for lack of standing and for failure to state a claim, and declined to exercise supplemental jurisdiction over the state-law claims. The estate appealed, challenging only the dismissal of its federal equal protection claims.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the estate lacked standing to bring the federal equal protection claims because the complaint did not allege that the decedent herself was personally denied equal protection by the Sheriff’s Office. Instead, the complaint described discriminatory treatment experienced by other women. The court explained that equal protection claims must be based on the plaintiff’s own legal rights, not those of third parties, and the estate did not qualify for the limited exception allowing third-party standing. As a result, the court affirmed the district court’s dismissal of the complaint in its entirety. View "Henry v. Blank" on Justia Law

The plaintiff applied for disability benefits from the Social Security Administration (SSA) but was denied at the agency level. She then sought judicial review in the United States District Court for the Northern District of Ohio. After the Commissioner of Social Security reviewed the case further, the Commissioner moved to remand the matter to the Administrative Law Judge (ALJ) for additional proceedings, specifically for further articulation regarding the persuasiveness of the evidence and further consideration of medical opinions. The Commissioner did not argue that the ALJ committed reversible error. The plaintiff agreed to a remand but requested that the court issue instructions to award her benefits outright.The district court granted the Commissioner’s motion for remand, reasoning that factual disputes remained and that it was not prepared to award benefits. The court remanded the case to the SSA for further consideration without affirming, modifying, or reversing the ALJ’s decision, and without expressly finding reversible error or making the specific predicate findings required for a remand under Sentence Six of 42 U.S.C. § 405(g). The plaintiff appealed the district court’s order.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that a district court may not remand a Social Security case under Sentence Four of 42 U.S.C. § 405(g) without explicitly affirming, modifying, or reversing the decision of the ALJ. The appellate court found that the district court’s order failed to comply with the requirements of either Sentence Four or Sentence Six and that district courts do not have inherent authority to issue other types of remand orders in Social Security cases. The Sixth Circuit therefore vacated the district court’s order and remanded the matter for further proceedings consistent with the opinion. View "Follen v. Commissioner of Social Security" on Justia Law

A man was convicted in Michigan of assault with intent to murder and various firearm offenses following a shooting incident. The case arose from a dispute involving the vandalism of homes, which led to a confrontation between the families of the victim and the accused. During the incident, several family members of the victim identified the accused as the shooter in photo lineups and at trial. The prosecution’s case relied heavily on these identifications and a recorded prison call, while the defense presented testimony from the accused’s sister, who suggested another individual committed the shooting. No physical evidence linked the accused to the crime.After his conviction, the defendant appealed to the Michigan Court of Appeals, arguing, among other things, that his trial counsel was ineffective for failing to call certain witnesses who could have provided an alibi or implicated another person. The appellate court affirmed his conviction, and the Michigan Supreme Court denied leave to appeal. The defendant then moved for post-conviction relief in Michigan state court, raising the same ineffective assistance claim, but the court found counsel’s decisions were reasonable and denied relief. Both the Michigan Court of Appeals and Supreme Court denied further review.The defendant subsequently filed a habeas petition in the United States District Court for the Eastern District of Michigan. The district court rejected the state’s timeliness objection and conditionally granted habeas relief on ineffective assistance grounds. On appeal, the United States Court of Appeals for the Sixth Circuit held that the habeas petition was untimely under the Antiterrorism and Effective Death Penalty Act (AEDPA), as the defendant’s state post-conviction motion did not toll the limitations period under Michigan law, and equitable tolling did not apply. The Sixth Circuit also found that, even if timely, the ineffective assistance claim failed on the merits. The court reversed the district court’s grant of habeas relief. View "Borns v. Chrisman" on Justia Law

Thomas O’Hara filed for Chapter 13 bankruptcy in early 2024. When the United States Trustee sought to dismiss his case, the bankruptcy court held a hearing and indicated it would convert the case to Chapter 7, unless O’Hara exercised his right to voluntarily dismiss under 11 U.S.C. § 1307(b) before the conversion order was entered. O’Hara did not file a motion to dismiss until after the bankruptcy court entered an order converting the case. His subsequent attempt to dismiss under § 1307(b) was denied, as was his later motion under Rule 60(b), in which he argued his delay should be excused as neglect and that his right to dismiss was circumvented.The United States District Court for the Western District of Michigan reviewed the bankruptcy court’s orders. The district court concluded that O’Hara’s appeals regarding the conversion and denial of dismissal were untimely, except for his timely appeal of the bankruptcy court’s denial of his Rule 60(b) motion. The district court affirmed the bankruptcy court, finding O’Hara’s Rule 60(b) motion meritless, as the case had already been converted before his dismissal motion was filed, and found no excusable neglect or extraordinary circumstances.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s affirmance. It held that its jurisdiction was limited to review of the August 7 order denying Rule 60(b) relief, as only that appeal was timely. The Sixth Circuit concluded that the bankruptcy court did not abuse its discretion in denying Rule 60(b) relief, because O’Hara’s failure to seek dismissal prior to conversion was a strategic decision, not excusable neglect, and his right to dismiss under § 1307(b) ceased once the case was converted. The court affirmed the district court’s decision and remanded for further proceedings. View "O'Hara v. Vara" on Justia Law

The case involves a defendant who was convicted by a jury of aiding and abetting kidnapping after an incident in Detroit. The events began when the defendant was shot during a confrontation involving rival gang members, after which the victim was taken by the defendant’s associates for interrogation. The victim was confined, threatened, and beaten at the defendant’s home, with parts of the incident recorded and later shared in an Instagram group chat. After these events, the victim was driven around, further assaulted, and eventually released.Prior to this appeal, the United States District Court for the Eastern District of Michigan oversaw the trial. The court denied the defendant’s motions to suppress evidence obtained from social media accounts, motions to exclude alleged co-conspirator statements, and ruled partially in favor of the government’s effort to limit cross-examination of the victim. After a weeklong trial, the jury acquitted the defendant of conspiracy but found him guilty of aiding and abetting kidnapping. The district court sentenced him to 198 months in prison and imposed several special conditions of supervised release, some of which were only included in the written judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. It affirmed the district court on four grounds: the denial of suppression motions, the admission of co-conspirator statements, the limitation on cross-examination, and the sufficiency of the evidence for conviction. The appellate court held that the defendant’s constitutional and evidentiary challenges failed. However, it found a discrepancy between the oral pronouncement of sentence and the written judgment regarding two special conditions of supervised release. The court remanded the case to the district court to resolve this discrepancy and, if needed, to consider the constitutional challenges to those conditions. View "United States v. Blake" on Justia Law

Brandie Nicole Appleton, along with an accomplice, burglarized a Tennessee pharmacy, stealing substantial quantities of controlled substances, firearm parts, and ammunition. After fleeing the scene and attempting to evade law enforcement, Appleton was apprehended, and the stolen items were recovered from her vehicle. Appleton subsequently pleaded guilty to possessing controlled substances with intent to distribute and possessing stolen ammunition. As part of her plea agreement, she waived her right to appeal any sentence within or below the Sentencing Guidelines range.The United States District Court for the Middle District of Tennessee determined Appleton’s Guidelines range to be 41 to 51 months of imprisonment but, noting her progress in overcoming addiction and her personal circumstances, sentenced her to five years of probation. The district court warned her of serious consequences if she violated any probation conditions. Approximately six weeks later, Appleton was arrested for possessing an unprescribed controlled substance, which constituted a violation of her probation. After a revocation hearing, the district court sentenced her to 44 months of imprisonment, within the original Guidelines range.The United States Court of Appeals for the Sixth Circuit reviewed Appleton’s appeal, in which she argued that the district court erred in imposing her sentence after revoking her probation. The government contended that her appeal was barred by the waiver in her plea agreement. The Sixth Circuit held that Appleton’s appeal waiver applied to any sentence within the Guidelines range, including one imposed after probation revocation for the same underlying offense. The court concluded that the waiver was knowingly and voluntarily made, encompassed her present claims, and did not fall under any exceptions. Therefore, the court dismissed her appeal. View "United States v. Appleton" on Justia Law

Over a five-year period, the defendant participated in a conspiracy to manufacture and distribute 16.1 million counterfeit alprazolam pills, which were sold via the dark web and other channels. The pills imitated the appearance and markings of legitimate FDA-approved alprazolam, but often contained benzodiazepine-class substances that were not scheduled as controlled substances at the time. The defendant marketed these pills as indistinguishable from legitimate products, and received payment in cryptocurrencies.The United States District Court for the Eastern District of Kentucky accepted the defendant’s guilty plea to conspiracy and counterfeiting charges. During sentencing, the court adopted the government’s proposed method for calculating loss under § 2B1.1 of the Sentencing Guidelines, using the estimated street price of $2 per pill to determine a total loss amount of approximately $32 million. The court also applied enhancements for victim numerosity or mass-marketing and for conscious or reckless risk of death or serious bodily injury, resulting in a total offense level of 35. The defendant was sentenced to 90 months’ imprisonment. Both parties objected to the loss calculation and enhancements, but the court overruled the objections after a joint evidentiary hearing.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s sentence. The appellate court held that the district court properly interpreted and applied Application Note 3(E)(v) of the Sentencing Guidelines, which requires loss to include the amount paid by end-users for misrepresented goods. It found no clear error in using the street price to calculate loss, nor in applying the enhancements for ten or more victims and for conscious or reckless risk of death or serious bodily injury. The sentence was affirmed in full. View "United States v. Wala" on Justia Law

Law enforcement officers responded to a report of an open door at Chad Taylor’s townhouse in Boone County, Kentucky. Inside, they found signs of recently fired gunshots, including bullet holes and spent shell casings. After obtaining search warrants, officers found ammunition and methamphetamine in Taylor’s possession. Taylor admitted to using methamphetamine and exhibited paranoid, erratic behavior, claiming people were watching him. The following day, Taylor was found at his home with a loaded Glock 19, and ballistics matched it to the earlier gunfire. Taylor had prior felony convictions for drug trafficking, intimidation, and misdemeanor domestic battery.A grand jury indicted Taylor for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The United States District Court for the Eastern District of Kentucky initially detained Taylor but later released him on conditions due to his history of substance abuse and the risk he posed. Taylor moved to dismiss the indictment, arguing that the statute was unconstitutional both facially and as applied. The district court denied the motion, finding Taylor dangerous based on his prior convictions, and subsequently sentenced him to 30 months’ imprisonment after he pled guilty but reserved his right to appeal the constitutional issue.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the constitutionality of § 922(g)(1) as applied to Taylor in light of recent circuit precedent. The appellate court held that the dangerousness assessment required for firearm disqualification is distinct from the assessment for pretrial detention. Applying the standard set forth in United States v. Williams, the court found that Taylor’s offense conduct and criminal history—including felony drug trafficking, intimidation, and domestic battery—demonstrated that he was dangerous. The court affirmed the district court’s judgment, holding that § 922(g)(1) is constitutional as applied to Taylor. View "United States v. Taylor" on Justia Law

An eighteen-year-old individual pleaded guilty in a Michigan court to a felony charge for carrying a concealed weapon. Rather than entering a judgment of conviction, the court placed him in a diversion program for youthful offenders under the Holmes Youthful Trainee Act, which deferred both conviction and judgment. The program allowed the court to enter a conviction at any time if the individual failed to meet its requirements. While still participating in this program and on probation, the individual was arrested and admitted possession of a firearm with an obliterated serial number, leading to federal charges.The United States District Court for the Western District of Michigan presided over the federal case. At sentencing, the court adopted the presentence report’s finding that the defendant’s offense level should be increased because he was a “prohibited person” under federal law at the time of the firearm offense, due to his pending felony charge in Michigan. The court concluded that the deferred status under the Michigan program meant the original felony information remained pending, qualifying him as being “under indictment” for purposes of federal firearms restrictions. The district court sentenced him to 48 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit considered whether participation in Michigan’s diversion program constituted being “under indictment,” thereby justifying the sentencing enhancement as a “prohibited person.” The Sixth Circuit held that, under Michigan law, the original felony charge remains pending throughout the diversion program until successful completion or revocation, and no judgment of conviction is entered unless the program is revoked. Consequently, the court affirmed that the defendant was “under indictment” during the relevant period, and thus properly subject to the federal sentencing enhancement. The judgment of the district court was affirmed. View "United States v. Rolon" on Justia Law