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

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In this case, the plaintiff, Jason Schwebke, brought a lawsuit against his employer, United Wholesale Mortgage (UWM), alleging disability discrimination under state and federal law. Schwebke, who is deaf, claimed that UWM failed to provide him with necessary accommodations and retaliated against him. In response, UWM participated in extensive discovery procedures for several months without invoking its right to arbitration as per the parties' employment agreement.Seven months into the case, UWM moved to compel arbitration. The district court denied this motion, reasoning that UWM had implicitly waived its right to compel arbitration through its conduct. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision.The appellate court applied the principle from the Supreme Court's decision in Morgan v. Sundance, Inc., which held that a party may waive its contractual right to arbitrate by participating in litigation. In applying this rule, the court found that UWM's actions—participating in extensive discovery, failing to raise arbitration in its defense, and not moving to compel arbitration until seven months into the case—were completely inconsistent with reliance on the arbitration agreement. The court therefore concluded that UWM had implicitly waived its right to arbitration. View "Schwebke v. United Wholesale Mortgage LLC" on Justia Law

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The court case involves Ferrellgas, L.P., which was appealing against an order enforcing a subpoena issued by the Equal Employment Opportunity Commission (EEOC). The subpoena was part of an EEOC investigation into a discrimination charge filed by an employee, alleging that Ferrellgas had engaged in discriminatory hiring, pay, and termination practices.Ferrellgas contended that the subpoena was improperly served, was facially invalid due to procedural errors, was overly broad, and would impose an undue burden. Ferrellgas also argued that the subpoena sought information on hiring practices, which was irrelevant to the specific discrimination charge. The United States Court of Appeals for the Sixth Circuit rejected all of Ferrellgas's arguments.The Court found that the subpoena was served properly, despite Ferrellgas's claims to the contrary. It also ruled that the procedural errors in the subpoena were harmless and did not preclude its enforcement. The Court concluded that the subpoena was not overly broad, as the information sought could shed light on the alleged discriminatory practices. The Court also held that Ferrellgas failed to demonstrate that complying with the subpoena would impose an undue burden.In conclusion, the Court affirmed the district court's order enforcing the EEOC's subpoena, deciding that the lower court did not abuse its discretion in doing so. View "EEOC v. Ferrellgas, L.P." on Justia Law

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In this case, the plaintiff, Kellie Farris, called 911 alleging that another woman had damaged her car. However, responding sheriff's deputies ended up arresting Farris instead. Farris alleged that during her arrest and subsequent transportation to jail, the deputies used excessive force. She also claimed that she was suicidal and that the deputies' actions were unreasonable given her state of mind.In response, the deputies argued that they had probable cause for Farris's arrest based on corroborated eyewitness testimony and physical evidence in Farris's car. They further contended that Farris's suicidal behavior justified the level of force used to restrain and control her.On reviewing the case, the United States Court of Appeals for the Sixth Circuit agreed with the lower court's decision to grant summary judgment in favor of the defendants. The court found that the deputies had probable cause for Farris's arrest and that the force used was minimal and reasonably necessary given Farris's behavior. The court also rejected Farris's claim that the county had an unconstitutional policy of inadequately training its deputies, finding no evidence of deliberate indifference or a pattern of excessive force.The court noted that states may pass laws or prison policies that protect detainees' privacy or liberty more than the Constitution demands, but Farris failed to show how this was relevant to her Fourth Amendment claim.In conclusion, the Sixth Circuit affirmed the district court's decision, ruling in favor of the deputies and the county on all counts. View "Farris v. Oakland County" on Justia Law

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A medical resident, Dr. Jacquelyn Mares, was dismissed from Wright State University’s (WSU) obstetrics and gynecology residency program due to ongoing complaints and escalating disciplinary actions related to her unprofessional behavior. Following her dismissal, Mares was also terminated from her position at Miami Valley Hospital, where she was employed during her residency. As a result, Mares sued WSU, the hospital, its owner-operator Premier Health Partners, and several WSU employees, alleging violations of her procedural and substantive due process rights, as well as various contract-based state law claims. The district court granted summary judgment to the defendants.In its ruling, the United States Court of Appeals for the Sixth Circuit held that WSU did not violate Mares' procedural due process rights when it dismissed her from the residency program. The court found that WSU had followed its internal procedures closely and that Mares was afforded more than enough process. Also, the court held that WSU did not violate Mares' substantive due process rights. It determined that WSU's decision to dismiss her was not arbitrary or capricious, nor was it conscience-shocking. Finally, the court held that Miami Valley Hospital did not breach its contractual duties when it terminated Mares after her dismissal from WSU’s residency program. The court concluded that the hospital acted within the scope of the employment contract. Therefore, the court affirmed the district court’s decision to grant the defendants' summary judgment. View "Mares v. Miami Valley Hospital" on Justia Law

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In this case, the United States Court of Appeals for the Sixth Circuit was presented with an appeal involving an Ohio hospital's mandate for its employees to get COVID-19 vaccines. The plaintiffs, a group of current and former employees who had requested religious exemptions from the mandate, sued the hospital for religious discrimination under Title VII and Ohio Revised Code § 4112 after the hospital initially rejected all religious exemptions. The district court dismissed the case for lack of subject matter jurisdiction and failure to state a claim, leading to this appeal.The appellate court affirmed the dismissal for the majority of plaintiffs, ruling they lacked standing to sue because they could not demonstrate sufficient injury. However, the court reversed the dismissal for two of the plaintiffs who had resigned after their religious exemption requests were denied but before the hospital changed its policy and granted all religious exemptions. The court held that these two plaintiffs had plausibly alleged that they were forced to resign, or "constructively discharged", and thus had standing to sue.Furthermore, the court found that these two plaintiffs had sufficiently alleged that the hospital failed to provide reasonable accommodations for their religious practices and treated them differently from other employees. Consequently, they had stated plausible claims for relief under Title VII and Ohio Revised Code § 4112. The case was remanded for further proceedings concerning these two plaintiffs. View "Savel v. MetroHealth System" on Justia Law

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Sandra Sabastian-Andres, an indigenous Mayan Akateko woman from Guatemala, appealed the Board of Immigration Appeals' affirmation of the Immigration Judge's decision to deny her claims for asylum, withholding of removal, and protection under the Convention Against Torture. Sabastian-Andres had fled to the U.S. after a man named Pedro threatened her for refusing his demand to become his wife and join his gang.The United States Court of Appeals for the Sixth Circuit reviewed the case under the substantial evidence standard, considering the Board's finding as reasonable, substantial, and probative evidence on the record as a whole. The court found substantial evidence supporting the Board's conclusion that there was no nexus between the threats Sabastian-Andres received and her identity as a Mayan Akateko woman. Sabastian-Andres's own testimony confirmed that Pedro's threats were not due to her indigenous identity.Additionally, substantial evidence supported the decision that Sabastian-Andres was ineligible for withholding of removal. Despite the less stringent standard for demonstrating a nexus in the context of withholding of removal compared to asylum, the complete lack of a nexus rendered her ineligible.Finally, the court found substantial evidence supporting the decision that Sabastian-Andres did not qualify for relief under the Convention Against Torture. Despite her claims that she could not report Pedro's threats to the police due to language barriers and her belief that the police collaborated with gangs, the court found that the Guatemalan government had taken steps to address gang violence. Therefore, the court denied Sabastian-Andres's petition for review. View "Sabastian-Andres v. Garland" on Justia Law

Posted in: Immigration Law
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In this case, a prisoner, Kyle Brandon Richards, appealed a district court's decision to dismiss his civil rights suit under 42 U.S.C. § 1983. The lawsuit was dismissed because Richards reportedly failed to exhaust his administrative remedies. The plaintiff alleged sexual harassment, retaliation, and destruction of property by Resident Unit Manager Thomas Perttu. Specifically, Richards claimed that Perttu prevented him from filing grievances related to the alleged abuse by destroying or ripping them up.The defendant, Perttu, moved for summary judgment, arguing that Richards had failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a). The district court denied the motion due to questions of fact. After an evidentiary hearing, a magistrate judge recommended that the district court find that Richards had failed to exhaust his administrative remedies. Richards appealed, alleging errors by the district court, bias by the magistrate judge, and the need for a free transcript of the evidentiary hearing.The United States Court of Appeals for the Sixth Circuit addressed whether the district court should have ordered an evidentiary hearing to decide the disputed questions of fact intertwined with the exhaustion issue. The Court of Appeals found that the Seventh Amendment required a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff’s substantive case. Therefore, the Court of Appeals reversed the judgment of the district court and remanded the case for further proceedings. View "Richards v. Perttu" on Justia Law

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The plaintiff, Tillman Transportation, LLC, and the defendant, MI Business, Inc. (operating as affiliate companies RDT and RDF) entered into three trucking contracts, each of which included arbitration clauses. After the contracts were terminated, disputes arose between the parties, leading to this lawsuit and a separate ongoing arbitration. The defendants moved to compel arbitration, arguing that the Federal Arbitration Act (FAA) requires enforcement of the arbitration clauses. Tillman contended that it was exempt from compulsory arbitration under Section 1 of the FAA.The district court granted the defendants’ motion to compel arbitration, ruling that Section 1 of the FAA, which exempts "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce" from the FAA's general policy favoring arbitration, did not apply to the arbitration clauses in the contracts because Tillman, as a limited liability company in contract with another corporate entity, did not qualify for the Section 1 exemption.Tillman appealed this decision. The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The Sixth Circuit held that the Section 1 exemption did not apply to an agreement between two corporate entities. Thus, the exemption did not apply to Tillman, a limited liability company. The court also noted that Tillman had waived certain arguments by failing to raise them in its initial brief on appeal. View "Tillman Transp., LLC v. MI Bus. Inc." on Justia Law

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The plaintiff, Ilya Kovalchuk, was driving his vehicle when off-duty police officer Matthew Ward began driving erratically behind him, ordered him to pull over, and held Kovalchuk at gunpoint without any justification. Kovalchuk filed a lawsuit against Ward and the City of Decherd, Tennessee, alleging that Ward violated his Fourth Amendment rights and that the City’s failure to investigate Ward’s background before hiring him led to Kovalchuk’s injuries. The district court dismissed the claims against the City, finding that Kovalchuk failed to adequately plead allegations supporting municipal liability.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court determined that in order to survive a motion to dismiss, a plaintiff must allege facts that, if accepted as true, are sufficient to state a claim to relief that is plausible on its face. The court found that Kovalchuk did not plausibly allege that the City of Decherd was deliberately indifferent to a known or obvious consequence of its decision to hire Ward. According to the court, Kovalchuk's allegations of "issues," "concerns about [Ward’s] demeanor and professionalism," and his "fail[ure] to complete [a] training program" were insufficient to establish a causal link between Ward's hiring and Kovalchuk's injury. The court further stated that a plaintiff cannot use discovery to bridge the gap between a deficient pleading and the possibility that a claim might survive upon further investigation. Therefore, the court affirmed the district court's dismissal of Kovalchuk's claims against the City of Decherd. View "Kovalchuk v. City of Decherd" on Justia Law

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The case involved Ricardo Alvarado, who was convicted of possessing a firearm as a felon under 18 U.S.C. § 922(g)(1). His crime was reported by officers who responded to a call that a man was carrying what appeared to be a machine gun in a mobile home park. Alvarado was found with a Ruger AR-556 semi-automatic rifle, and upon investigation, officers discovered that he had two prior felony convictions. He was sentenced to 104 months' imprisonment, including a four-level sentencing enhancement for reckless endangerment.Alvarado appealed his conviction and sentence. He contended that his conviction violated the Second Amendment based on the standard articulated in New York State Rifle & Pistol Ass’n v. Bruen, an issue he raised for the first time on appeal. He also argued that the evidence did not support a sentencing enhancement for reckless endangerment.The United States Court of Appeals for the Sixth Circuit affirmed Alvarado’s conviction but vacated his sentence and remanded the case to the district court for resentencing. The court found that the constitutionality of § 922(g)(1) under Bruen was subject to reasonable dispute and would not disturb Alvarado’s conviction on plain error review. However, the court found that the district court erred in applying a sentencing enhancement for reckless endangerment. Without record evidence of anyone in proximity to Alvarado’s line of fire, or otherwise facing an imminent risk of harm, the Government could not satisfy Tennessee’s zone of danger requirement. Consequently, Alvarado's sentence was vacated. View "United States v. Alvarado" on Justia Law