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

The plaintiff, Laurie DeVore, worked at the University of Kentucky from 1999 to 2022. She retired rather than comply with the University's COVID-19 test-or-vaccinate policy, which she claimed conflicted with her religious beliefs. DeVore filed a lawsuit alleging that the University violated Title VII of the Civil Rights Act of 1964 by failing to accommodate her religious beliefs. The University had denied her requests for a hybrid work schedule and religious exemptions from the testing policy, which required unvaccinated employees to undergo weekly COVID-19 testing.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the University. The court found that DeVore did not establish a prima facie case of religious discrimination because she failed to demonstrate that the University's policy conflicted with her sincerely held religious beliefs. DeVore appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court examined whether DeVore had a sincere religious belief that conflicted with the University's testing policy. DeVore's objections to the nasal PCR tests were initially based on invasiveness, manipulation, and coercion. However, the University offered alternative testing methods, such as oral swab and saliva tests, which DeVore also rejected without providing evidence of a religious conflict with these alternatives.The Sixth Circuit affirmed the district court's decision, holding that DeVore failed to establish a conflict between her religious beliefs and the University's testing policy. The court noted that DeVore's objections were largely based on personal moral codes and secular concerns rather than religious principles. Consequently, DeVore's Title VII claim did not succeed. View "DeVore v. University of Kentucky Board of Trustees" on Justia Law

Following an accident, Jeremy Marchek sued his auto insurer, United Services Automobile Association (USAA), claiming that the company breached the terms of the policy it issued to him. Marchek argued that USAA wrongfully failed to compensate him for sales taxes and mandatory fees necessary to purchase a replacement vehicle after USAA declared his vehicle to be beyond repair. USAA paid Marchek the pre-accident value of his vehicle minus a deductible but did not include taxes and fees in the payment.The United States District Court for the Western District of Michigan dismissed Marchek’s complaint, ruling that USAA was not contractually obligated to compensate him for taxes and fees. The district court found that the insurance policy did not require USAA to cover these additional costs when calculating the actual cash value (ACV) of the vehicle.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that the plain language of the insurance policy plausibly requires USAA to compensate Marchek for the sales taxes and mandatory fees necessary to purchase a replacement vehicle. The court found that the policy’s definition of ACV, which is “the amount that it would cost, at the time of loss, to buy a comparable vehicle,” does not unambiguously exclude taxes and fees. Therefore, the case was remanded for further proceedings to determine whether USAA breached the contract by not including these costs in its payment to Marchek. View "Marchek v. United Services Automobile Association" on Justia Law

The defendant, Sylvester Gailes, has a history of domestic violence, including multiple incidents where he physically assaulted his partners. In 2012, he struck his girlfriend in the face, and in 2014, he dragged her by her hair and kicked her in the head. In 2018, he assaulted another ex-girlfriend, choking her and threatening her with a handgun. Gailes was convicted of domestic-violence misdemeanors for each of these incidents. Later, during a traffic accident investigation, police found Gailes in possession of two loaded pistols, leading to his indictment for violating 18 U.S.C. § 922(g)(9), which prohibits individuals convicted of domestic-violence misdemeanors from possessing firearms.The United States District Court for the Western District of Tennessee denied Gailes's motion to dismiss the indictment, in which he argued that 18 U.S.C. § 922(g)(9) is unconstitutional in light of the Supreme Court's decision in New York State Rifle & Pistol Ass’n v. Bruen. Gailes then pleaded guilty to the charges and was sentenced to 50 months in prison. He appealed the district court's decision, challenging the constitutionality of the statute under the Second Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court applied the two-step framework from Bruen, first determining that the Second Amendment's plain text covers Gailes's conduct. The court then examined whether the statute is consistent with the Nation's historical tradition of firearm regulation. The court found that historical analogues, such as surety laws and "going armed" laws, support the constitutionality of disarming individuals who pose a clear threat of physical violence. Consequently, the court held that 18 U.S.C. § 922(g)(9) is facially constitutional and affirmed the district court's judgment. View "United States v. Gailes" on Justia Law

Ohio enacted a law to prevent foreign nationals from influencing its elections by banning their political contributions and expenditures. The law defines "foreign nationals" to include lawful permanent residents, unlike the Federal Election Campaign Act (FECA), which exempts them. Plaintiffs, including advocacy organizations and lawful permanent residents, challenged the law on First Amendment grounds, arguing it violated their rights. The district court agreed, finding the law unconstitutional as applied to lawful permanent residents and issued a preliminary injunction preventing Ohio from enforcing the law against all foreign nationals.The United States District Court for the Southern District of Ohio granted the preliminary injunction, reasoning that the law was overbroad and violated the First Amendment rights of lawful permanent residents. The court allowed Ohio to enforce the law against foreign governments and political parties but severed the definition of "foreign national" to exclude lawful permanent residents. Ohio appealed the decision and requested an emergency stay of the injunction.The United States Court of Appeals for the Sixth Circuit reviewed the case and granted Ohio's motion for a stay. The court found that Ohio was likely to succeed on the merits, concluding that the law was not overbroad and did not violate the First Amendment rights of lawful permanent residents. The court held that Ohio has a compelling interest in preventing foreign influence in its elections, which includes lawful permanent residents. The court also determined that the law was narrowly tailored to serve this interest and was neither overinclusive nor underinclusive. The stay allows Ohio to enforce the law while the appeal is considered. View "OPAWL - Building AAPI Feminist Leadership v. Yost" on Justia Law

Christopher Goins challenged the constitutionality of 18 U.S.C. § 922(g)(1), which prohibits firearm possession by individuals convicted of crimes punishable by imprisonment for over a year. Goins, with multiple felony convictions, argued that the Supreme Court's decision in New York State Rifle and Pistol Association, Inc. v. Bruen rendered this statute unconstitutional as applied to him. In December 2021, Goins had an associate purchase a firearm for him, which he then took possession of, despite being on probation with a condition prohibiting firearm possession.The United States District Court for the Eastern District of Kentucky denied Goins's motion to dismiss the indictment, holding that § 922(g)(1) was constitutional as applied to him. Goins pled guilty but reserved the right to appeal the district court's decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and upheld the district court's decision. The court found that Goins's probation condition, his relatively short probation sentence for a dangerous crime, and his repeated dangerous conduct justified his disarmament under the Second Amendment. The court emphasized that historical traditions support the temporary disarmament of individuals who have engaged in dangerous conduct, such as Goins. Therefore, the court held that 18 U.S.C. § 922(g)(1) is constitutional as applied to Goins and affirmed the district court's judgment. View "United States v. Goins" on Justia Law

In this case, the defendant was charged with possessing a stolen firearm and receiving a firearm while under felony indictment. Law enforcement found the stolen firearm in a vehicle owned by another individual, who later revealed that the defendant had left the gun in his car. The defendant admitted to touching the gun and knowing it was stolen. He was under felony indictment for other firearms offenses at the time.The United States District Court for the Southern District of Ohio denied the defendant's motion to dismiss the indictment, which argued that the statutes under which he was charged violated the Second Amendment. During jury selection, the defendant raised a Batson challenge against the prosecutor's peremptory strike of the last black juror on the panel. The district court found the prosecutor's reasons for the strike to be race-neutral and allowed it. The jury convicted the defendant on both counts, and he was sentenced to 18 months' imprisonment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court upheld the district court's denial of the motion to dismiss, finding that the statutes in question were consistent with historical firearm regulations and did not violate the Second Amendment. The court also affirmed the district court's rejection of the Batson challenge, concluding that the prosecutor's race-neutral explanation for the peremptory strike was credible and not pretextual. The Sixth Circuit affirmed the defendant's conviction and sentence. View "United States v. Gore" on Justia Law

Timothy Hall participated in a protest in Detroit, where he was tackled and injured by a City of Detroit officer. Later, another officer ticketed him for disorderly conduct. Hall filed two lawsuits: one against the City of Detroit and another against the officers, claiming retaliation for exercising his First Amendment rights. The district court consolidated the suits, denied Hall’s request to extend the discovery period, granted summary judgment to the City, but denied the ticketing officer’s claim of qualified immunity.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the City of Detroit, dismissing Hall’s claims against the City. However, the court denied the ticketing officer’s motion for summary judgment on the grounds of qualified immunity, allowing Hall’s First Amendment retaliation claim to proceed. Hall appealed the denial of his motion to extend the discovery period and the summary judgment in favor of the City, while the ticketing officer appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of Hall’s motion to extend the discovery period and the grant of summary judgment to the City. However, the appellate court reversed the district court’s decision denying the ticketing officer’s motion for summary judgment on the grounds of qualified immunity. The court held that the officer was entitled to qualified immunity because it was not clearly established that issuing a ticket under the circumstances violated Hall’s First Amendment rights. The court emphasized that the officer acted on plausible instructions from a superior and had no reason to doubt the legitimacy of the order. View "Hall v. Navarre" on Justia Law

Art Iron, Inc. faced a lawsuit from the Board of Trustees of the Shopmen’s Local 499 Pension Plan seeking over one million dollars in withdrawal liability under ERISA. The key issue was whether Robert Schlatter, Art Iron’s sole shareholder, and his wife, Mary Schlatter, were personally liable for this withdrawal liability due to their operation of businesses allegedly under common control with Art Iron.The United States District Court for the Northern District of Ohio granted summary judgment in favor of the Board, finding both Robert and Mary Schlatter personally liable. The court determined that Robert’s consulting business and Mary’s jewelry-making activities were trades or businesses under common control with Art Iron, thus making them jointly and severally liable for the withdrawal liability.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s judgment regarding Robert Schlatter, agreeing that his consulting business was a trade or business under common control with Art Iron. The court applied the Groetzinger test, which considers whether the activity is continuous and regular and primarily for income or profit, and found that Robert’s consulting business met these criteria.However, the court reversed the district court’s judgment regarding Mary Schlatter. It found that her jewelry-making activities did not constitute a trade or business under the Groetzinger test, as her activities lacked the necessary continuity and regularity in 2017, the year of Art Iron’s withdrawal from the Plan. Consequently, Mary Schlatter was not personally liable for the withdrawal liability.The Sixth Circuit thus affirmed the district court’s judgment as to Robert Schlatter and reversed and remanded the judgment as to Mary Schlatter. View "Shopmen’s Local No 499, Bd of Trustees v. Art Iron, Inc." on Justia Law

The case involves Robert Holman, who challenged a debt-relief program under the American Rescue Plan Act that provided benefits to "socially disadvantaged" farmers and ranchers based on racial categories. Holman, a farmer, argued that he was excluded from the program solely due to his race and sought a preliminary injunction to halt the program. The district court granted the preliminary injunction, finding that the program did not meet the strict scrutiny standard required for racial classifications under the Fifth Amendment. However, before a final judgment was reached, Congress repealed the program, leading Holman to seek attorney's fees under the Equal Access to Justice Act (EAJA).The United States District Court for the Western District of Tennessee denied Holman's request for fees, ruling that he was not a "prevailing party" under the EAJA because the preliminary injunction did not provide him with lasting relief. The court also noted that the injunction was temporary and revocable, and thus did not materially alter the legal relationship between the parties.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court did not definitively rule on whether Holman was a "prevailing party" but found that the Government's position during the litigation was "substantially justified" under the EAJA. The court noted that the Government had presented substantial evidence to defend the program's constitutionality, including historical discrimination against minority farmers by the USDA. The court concluded that a reasonable person could find the Government's position justified, thereby precluding Holman's entitlement to attorney's fees and expenses. View "Holman v. Vilsack" on Justia Law

A police officer with over thirty-three years of experience, including seventeen years with the Blue Ash Police Department, was terminated at age sixty-one. The officer alleged that his performance record was nearly perfect until a new police chief took over, after which he faced increased scrutiny and discipline. The officer was assigned a traffic study, typically not given to patrol officers, and disciplined multiple times for minor infractions, including failing to turn on his microphone during traffic stops and not responding promptly to a noise complaint. The final incident leading to his termination involved a delayed response to a medical emergency, which led to an investigation uncovering multiple policy violations, including untruthfulness.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants on all claims. The court concluded that the officer failed to provide sufficient evidence that his termination was due to age discrimination. The court also found that the officer abandoned his other claims by not addressing them in his brief opposing summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision regarding the age discrimination claim, holding that the officer could not show that age was the "but-for" reason for his termination. However, the court reversed the district court's decision on the hostile work environment claim. The appellate court found that the officer presented enough evidence to create a genuine dispute of material fact regarding whether he was subjected to a hostile work environment based on age. The court noted that the officer's allegations of increased scrutiny, disproportionate discipline, and demeaning assignments could support a hostile work environment claim. The case was remanded for further proceedings on this claim against the City of Blue Ash. View "McNeal v. City of Blue Ash" on Justia Law