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

The case revolves around Joshua Aldridge, who was found guilty of conspiracy to sex traffic an adult by force, threats of force, fraud, or coercion, among other charges. Aldridge and his girlfriend, Kathy, were both addicted to painkillers and sought out higher-dosage pills from Larry Dean Porter. When they could not afford to purchase pills with money, Porter would allow them to have the pills as long as they agreed to pay him later. Eventually, Kathy was informed that she could “work off” the debt by “cleaning and doing sexual favors.” Aldridge would regularly drive Kathy to Porter’s house, take his pill, leave Kathy at the house, and return to pick her up when she was finished.The district court denied Aldridge's Rule 29 motion for judgment of acquittal on the adult-sex-trafficking-by-force conspiracy charge. The court reasoned that a jury could find that Aldridge had personally coerced Kathy to buy pills in exchange for sex acts. The jury found Aldridge guilty on all three counts. At sentencing, the district judge applied two enhancements over Aldridge’s objections: the enhancement for use of a computer to entice or offer and the vulnerable-victim enhancement.In the United States Court of Appeals for the Sixth Circuit, Aldridge challenged the district court’s denial of his Rule 29 motion and the district court’s application of two sentencing enhancements. The court affirmed the district court's decision, stating that there was sufficient evidence for the jury to find that Aldridge knowingly and voluntarily joined the conspiracy with intent to further its objective. The court also found that the district court properly applied the sentencing enhancements. View "United States v. Aldridge" on Justia Law

The case involves Keeley Hamilton, who applied for disability insurance benefits and supplemental security income from the Social Security Administration (SSA) due to her physical impairments. An administrative law judge (ALJ) within the SSA denied her applications, concluding that despite her physical impairments, she could still work in two occupations. Hamilton appealed, arguing that she should be considered disabled unless she could work in at least three occupations, a rule she derived from Ninth Circuit caselaw.Hamilton's applications were initially denied by an ALJ, who found that she could still work in two occupations despite her physical impairments. The district court remanded the case back to the SSA for further proceedings, citing a failure to ask the vocational expert about potential conflicts between his testimony and the occupational information in the Dictionary of Occupational Titles. On remand, the ALJ held another hearing and again denied Hamilton's applications, concluding that Hamilton's skills permitted her to perform two semi-skilled sedentary occupations: food checker and auction clerk.In the United States Court of Appeals for the Sixth Circuit, Hamilton argued that the ALJ should have found her disabled because his findings showed that her skills did not transfer to at least three occupations. The court disagreed with Hamilton's interpretation of the rule, stating that the ALJ did not err by ruling that Hamilton was not disabled under the regulations because she had skills that transferred to a significant range of work. The court affirmed the district court's decision upholding the Social Security Administration's denial of benefits to Hamilton. View "Hamilton v. Comm'r of Soc. Sec." on Justia Law

The case involves Katrina Robinson, founder and director of The Healthcare Institute (THI), a for-profit company in Memphis, Tennessee, that provided certified nursing assistant training. THI received a federal grant from the Geriatrics Workforce Enhancement Program (GWEP), administered by the Health Resources and Services Administration (HRSA), from 2015 to 2019. The grant provided scholarships for eligible THI students. Robinson was convicted of four counts of wire fraud for actions she took in administering the grant. The district court granted Robinson's post-verdict motion for a judgment of acquittal on two of the counts, and Robinson appealed the denial of acquittal on the remaining two counts.The district court's decision was based on a federal investigation that raised concerns about Robinson's use of HRSA grant funds for personal expenses and discrepancies in Annual Performance Reports (APRs) that Robinson had submitted on THI’s behalf. The APRs contained inaccurate information on the number of students who graduated from the program, the number of students who received grant-funded scholarships, and the unique numerical identifiers assigned to students. The government argued that these "errors" were intentional manipulations by Robinson to ensure THI’s continued receipt of grant funds.The United States Court of Appeals for the Sixth Circuit affirmed in part, reversed in part, and remanded for further proceedings. The court found that there was sufficient evidence to prove that Robinson's submission of false information in the APRs constituted a course of conduct intended to deprive the government of money. The court also found that Robinson's intent to defraud was demonstrated by her direct involvement in preparing and submitting the APRs, and her direction to charge personal wedding expenses to the grant. The court reversed the district court's grant of acquittal on one of the counts, finding that a rational juror could conclude that Robinson's transmission of materially false information was done to induce HRSA to continue funding the grant. The court affirmed the district court's denial of acquittal on the remaining two counts. View "United States v. Robinson" on Justia Law

The case involves Dr. Euna McGruder, who was terminated from her position as the Executive Officer of Priority Schools for the Nashville public school system, operated by Metro Nashville, after she investigated allegations of racial discrimination at a Nashville middle school. McGruder sued Metro Nashville in 2017, alleging that her termination constituted illegal retaliation in violation of Title VII. In 2021, a jury awarded McGruder $260,000 for her claim, and the district court ordered Metro Nashville to reinstate her to her previous position.After the trial, Metro Nashville discovered that McGruder had failed to disclose the existence of her Title VII claim to the bankruptcy court when she filed for Chapter 7 bankruptcy in 2018. Metro Nashville argued that McGruder's claims should be barred by judicial estoppel due to her failure to disclose her cause of action against Metro Nashville in her bankruptcy filing. The district court concluded that it could not exercise jurisdiction over Metro Nashville’s judicial estoppel claim, given that Metro Nashville’s earlier notice of appeal had divested the court of jurisdiction over the case.The United States Court of Appeals for the Sixth Circuit affirmed the district court's reinstatement order and dismissed Metro Nashville's appeal for lack of jurisdiction. The court held that judicial estoppel does not bar McGruder's reinstatement. The court also found that the district court did not abuse its discretion in ordering McGruder's reinstatement. The court did not have jurisdiction to apply judicial estoppel to the non-final and therefore non-appealable jury award, forthcoming back pay trial, or award of attorneys’ fees. View "McGruder v. Metro. Gov't of Nashville" on Justia Law

The case involves Carl Hubbard, who was convicted of first-degree murder in Michigan state court in 1992. Over two decades later, Hubbard filed a petition for a writ of habeas corpus in the United States District Court for the Eastern District of Michigan, arguing that he is entitled to an equitable exception to the Antiterrorism and Effective Death Penalty Act of 1996’s (AEDPA) time bar based on a credible showing of actual innocence. The district court dismissed the petition as untimely.The district court's decision was appealed to the United States Court of Appeals for the Sixth Circuit. Hubbard argued that he had new evidence that impeached the State’s case against him, but he failed to present evidence affirmatively demonstrating his actual innocence. The court held that AEDPA does not permit him to file an untimely habeas petition. The court affirmed the district court's decision, stating that Hubbard's new evidence did not meet the burden of showing that the State had imprisoned an innocent person. Therefore, Hubbard must comply with the same law with which all other habeas petitioners must comply. View "Hubbard v. Rewerts" on Justia Law

Travis Lester, a convicted felon, was arrested and charged with possession of a firearm after law enforcement officers found a stolen .40 caliber pistol in his motel room. The arrest occurred after Lester violated the terms of his supervised release from a previous conviction for possessing ammunition as a felon. During the arrest, officers found a baggie of crack cocaine and $869 in cash on Lester's person. Lester admitted to having marijuana in his motel room. Based on this information, officers obtained a search warrant for the room, where they found the pistol, a digital scale, and a small bag of marijuana.Prior to his trial, Lester filed a motion to suppress the evidence obtained from the officers' protective sweep of his motel room and his admission about the marijuana, arguing that these violated his Fourth Amendment and Miranda rights. The district court denied this motion, finding that the officers had not violated Lester's rights. At trial, the jury convicted Lester, and the district court sentenced him to 120 months in prison. The court also imposed an additional seventeen-month prison sentence to be served consecutively due to Lester's violation of the supervised-release conditions from his earlier conviction.On appeal to the United States Court of Appeals for the Sixth Circuit, Lester argued that his Miranda and Fourth Amendment rights were violated, that there were evidentiary errors, and that there were mistakes in his sentencing. The appellate court disagreed with Lester's claims and affirmed the district court's decision. The court held that the officer's question during Lester's arrest was not an interrogation under Miranda, and that the protective sweep of Lester's motel room did not violate his Fourth Amendment rights. The court also found no error in the district court's evidentiary rulings or in its sentencing of Lester. View "United States v. Lester" on Justia Law

The case involves Kamel Chaney-Snell, who was arrested by Deputy Andrew Young and Officer Andrew Teichow during a search of his girlfriend's house. Chaney-Snell claimed that after he peacefully surrendered, Young punched him in the face, and one of the officers kneed him in the back and dragged him across the floor. He sued Young and Teichow under 42 U.S.C. § 1983, alleging excessive force and failure to intervene. The district court denied qualified immunity to both officers.The officers' appeals raised three questions. First, whether the court must accept Chaney-Snell’s claim that Young gratuitously punched him despite Chaney-Snell’s guilty plea for attempting to resist arrest. The Sixth Circuit found that it lacked jurisdiction over Young’s Heck claim, and his judicial-estoppel claim failed on the merits.Second, whether the Fourth Amendment allows officers to use unnecessary force on arrestees if the force qualifies as “de minimis”. The court held that gratuitous force violates the Fourth Amendment even if the force is minor and causes no serious injury.Finally, whether Chaney-Snell established a “failure to intervene” theory of liability. The court found that qualified immunity protects the officers from Chaney-Snell’s failure-to-intervene claims.The Sixth Circuit affirmed in part, reversed in part, and dismissed in part for lack of jurisdiction. View "Chaney-Snell v. Young" on Justia Law

The case involves Hattie Tanner, who was convicted of murder and served seventeen years in prison before her conviction was set aside due to insufficient evidentiary support. After her release, Tanner filed a lawsuit against David Walters, a retired police detective, alleging that he violated her constitutional rights by falsifying investigation reports and providing false testimony, leading to her wrongful conviction. Walters sought summary judgment based on qualified immunity, which the district court partially granted and partially denied. The court allowed Tanner's claims for fabrication of evidence and malicious prosecution to proceed to trial. Walters appealed this decision.Previously, the district court found that Tanner's claims for fabrication of evidence and malicious prosecution should proceed to trial. Walters appealed this decision, arguing that he was entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that a reasonable jury could conclude that Walters knowingly fabricated evidence against Tanner, and thus he was not entitled to qualified immunity on Tanner's fabrication-of-evidence claim. The court also found that a reasonable jury could find that Walters's false statements influenced the decision to charge Tanner, and that without these false statements, there would not have been probable cause to prosecute Tanner. Therefore, Walters was not entitled to qualified immunity on Tanner's malicious prosecution claim. View "Tanner v. Walters" on Justia Law

The case involves a dispute between Firexo Group Limited (FGL), a British company that manufactures fire extinguishers, and Firexo, Inc., a Florida-based company that was created to sell FGL's products in the United States. Scot Smith, a resident of Ohio, purchased 70% of Firexo, Inc. from FGL under a Joint Venture Agreement (JVA). The JVA included a forum-selection clause designating England or Wales as the exclusive jurisdiction for any disputes arising from the agreement. Firexo, Inc., which was not a signatory to the JVA, later sued FGL in an Ohio court over issues with the fire extinguishers. FGL sought to dismiss the case based on the forum-selection clause in the JVA.The district court granted FGL's motion to dismiss, applying the "closely related" doctrine. This doctrine allows a non-signatory to a contract to be bound by a forum-selection clause if the non-signatory is sufficiently closely related to the contract. The district court found that Firexo, Inc. was closely related to the JVA and therefore subject to the forum-selection clause. Firexo, Inc. appealed this decision, arguing that the district court applied the wrong law and analytical approach in determining the applicability of the contract.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The appellate court agreed with Firexo, Inc. that the district court had applied the wrong law. The court held that the "closely related" doctrine, a federal common law rule, should not have been used to interpret the JVA's forum-selection clause. Instead, the court should have applied the law specified in the JVA, which was English law. Under English law, contracts do not apply to non-signatories unless certain exceptions apply, none of which were present in this case. Therefore, the forum-selection clause in the JVA did not apply to Firexo, Inc., and the case was remanded for further proceedings. View "Firexo, Inc. v. Firexo Group Limited" on Justia Law

Sedric Ward, an Army reservist, worked at the Shelby County Jail. In 2015, the County fired Ward but later entered into a settlement agreement in which Ward released “any and all claims whatsoever” related to his termination. Despite this, Ward later sued the County under the Uniformed Services Employment and Reemployment Rights Act (USERRA). The central issue was whether the settlement agreement effectively released Ward’s claim under the Act.The district court ruled in favor of Ward, asserting that the release’s scope—namely, “any and all claims whatsoever”—did not reach his USERRA claim. The case went to trial, and the jury found in Ward’s favor. The district court eventually ordered the County to pay Ward more than $1.5 million.The United States Court of Appeals for the Sixth Circuit disagreed with the district court's reasoning. The appellate court found that the release provision in the settlement agreement clearly encompassed Ward’s USERRA claim. However, the court also noted that USERRA imposes a second requirement for the release of a claim under the Act. Specifically, the Act requires that the agreement “establish” rights that are “more beneficial” for the servicemember than the ones he gives up. The court found that whether a particular settlement agreement provides greater benefits than a USERRA claim is for the servicemember to decide. Given the circumstances, the court concluded that a reasonable jury could find that Ward’s decision to enter into the agreement reflected a considered decision on his part, or instead that it reflected only desperation. The appellate court vacated the district court’s judgment and remanded the case for further proceedings. View "Ward v. Shelby County" on Justia Law