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

Georgia-Pacific Consumer Products LP and other plaintiffs incurred cleanup costs at a site on the Kalamazoo River in Michigan due to pollution from paper mills. In 1995, Georgia-Pacific and other companies formed the Kalamazoo River Study Group (KRSG) and sought a declaration of shared liability for cleanup costs under CERCLA § 107. In 1998, the district court declared KRSG members, including Georgia-Pacific, liable for the entire cost of response activities at the site. Subsequent judgments in 2000 and 2003 confirmed this liability.In 2010, Georgia-Pacific filed a lawsuit against NCR Corporation, International Paper Company, and Weyerhaeuser Company, asserting claims under both CERCLA § 107(a) and § 113(f) for cleanup costs. The district court found NCR and International Paper liable and apportioned liability among the parties. However, the Sixth Circuit Court of Appeals held that Georgia-Pacific’s § 113(f) claims were time-barred and that Georgia-Pacific could not pursue § 107(a) claims for costs within the scope of the 1998 judgment.On remand, the district court vacated its judgment under § 113(f) but re-entered a declaratory judgment under § 107, declaring Georgia-Pacific, International Paper, and Weyerhaeuser liable for future response costs. International Paper and Weyerhaeuser appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and vacated the district court’s declaratory judgment under § 107. The court held that Georgia-Pacific could not pursue a § 107(a) claim for costs within the scope of the 1998 judgment, as those costs were recoverable only under § 113(f). The court remanded the case for further proceedings to determine the scope of the 1998 judgment and allowed Georgia-Pacific to bring § 107(a) claims for costs outside that scope. View "Georgia-Pacific Consumer Products LP v. NCR Corp." on Justia Law

Michael Poffenbarger, a First Lieutenant in the Air Force Reserve, filed a lawsuit challenging the Air Force’s COVID-19 vaccine mandate, claiming it violated the Religious Freedom Restoration Act (RFRA) and the First Amendment. He sought a religious exemption, which was denied, and subsequently refused the vaccine. As a result, he received a letter of reprimand and was placed on inactive status, losing pay and retirement points. Poffenbarger sought declaratory and injunctive relief, including restoration of lost pay and points.The United States District Court for the Southern District of Ohio initially granted a preliminary injunction preventing the Air Force from taking further punitive action against Poffenbarger. In a related case, Doster v. Kendall, the same court certified a class of affected service members and issued similar injunctions. The Sixth Circuit affirmed these injunctions, but the Supreme Court later vacated the decision on mootness grounds after Congress directed the rescission of the vaccine mandate. The district court then dismissed Poffenbarger's case as moot.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The court held that Poffenbarger’s claim for lost drill pay and retirement points was barred by federal sovereign immunity. The court explained that RFRA’s waiver of sovereign immunity does not unequivocally include claims for money damages against the federal government. Since Poffenbarger’s claim sought retrospective compensation for a previous legal wrong, it constituted money damages, which are not covered by RFRA’s waiver. Consequently, the Sixth Circuit affirmed the district court’s dismissal of the case. View "Poffenbarger v. Kendall" on Justia Law

John Doe, a convicted sex offender, challenged the enforcement of Tennessee's sex-offender statutes against him, arguing that the requirements imposed by these statutes constituted retroactive punishment in violation of the Constitution’s Ex Post Facto Clause. Tennessee's sex-offender statutes require offenders to register with the Tennessee Bureau of Investigation, update their personal information quarterly, limit where they can live and work, and allow the state to publish information about registrants. Doe committed his offenses before the passage of the 2004 statutes and sought to prevent Tennessee officials from enforcing these laws against him.The United States District Court for the Middle District of Tennessee issued a preliminary injunction barring Tennessee officials from enforcing any of the state’s sex-offender statutes against Doe. This decision was influenced by a related case, Does #1–9 v. Lee, where the district court had issued a similar injunction for nine other convicted sex offenders. After the Sixth Circuit reviewed Does #1–9, it held that the plaintiffs lacked standing to sue the governor and directed the trial court to modify its injunction against the director, stating that the district court had misinterpreted precedent and that only specific provisions of the sex-offender statutes could be enjoined.The United States Court of Appeals for the Sixth Circuit reviewed the district court's refusal to dissolve or modify the preliminary injunction following the Does #1–9 decision. The Sixth Circuit held that the district court abused its discretion by not dissolving or modifying the injunction, as the Does #1–9 decision clarified that the injunction was overly broad. The Sixth Circuit reversed the district court’s order administratively closing the case and remanded for proceedings consistent with the Does #1–9 opinion, instructing the district court to determine which specific provisions of Tennessee’s sex-offender statutes could be enjoined. View "Doe v. Lee" on Justia Law

In 2017, Gratiot County foreclosed on Donald Freed’s home due to unpaid taxes. Freed’s property, valued at $98,800, was sold for $42,000, although he owed just under $1,110. The county kept all proceeds from the sale, as Michigan’s General Property Tax Act (GPTA) did not require returning surplus proceeds to the property owner. Freed sued Gratiot County and its treasurer, Michelle Thomas, under 42 U.S.C. § 1983, claiming a violation of the Fifth and Fourteenth Amendments. Michigan intervened to defend the GPTA’s constitutionality.The United States District Court for the Eastern District of Michigan dismissed Freed’s complaint for lack of subject matter jurisdiction, citing Wayside Church v. Van Buren County. Freed appealed, and the Sixth Circuit reversed the dismissal, recognizing that the Supreme Court’s ruling in Knick v. Township of Scott partially abrogated Wayside Church. On remand, the district court granted partial summary judgment to Freed, affirming that the county had to pay Freed the difference between the foreclosure sale and his debt, but dismissed claims against Thomas due to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed Freed’s entitlement to attorneys’ fees from Gratiot County and Michigan. However, the court vacated the district court’s fee calculation and remanded for further proceedings. The Sixth Circuit held that Freed prevailed against both Gratiot County and Michigan, and Michigan’s intervention under 28 U.S.C. § 2403(b) subjected it to attorneys’ fee liability. The court found the district court’s explanation for reducing Freed’s hours and rate by 35% insufficient and required a more detailed justification for the fee award calculation. View "Freed v. Thomas" on Justia Law

In September 2020, Jesse Fairley was observed by law enforcement conducting hand-to-hand drug transactions in a convenience store parking lot. When officers approached and searched the vehicle Fairley had been using, they found crack cocaine, marijuana, cash, and two loaded firearms. Fairley was charged and convicted of possessing with intent to distribute crack cocaine, being a felon in possession of firearms, and possessing a firearm in furtherance of a drug trafficking crime. He received a thirty-year sentence and appealed his conviction.The United States District Court for the Northern District of Ohio denied Fairley's motions for acquittal, finding sufficient evidence for the jury to convict him. Fairley raised five issues on appeal, including the sufficiency of the evidence, the jury instructions on third-party guilt, the cumulative effect of evidentiary rulings, alleged improper communications with a defense witness, and improper closing remarks by the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the lower court's decision. The court found that there was substantial evidence to support Fairley's convictions, including his proximity to the drugs and firearms, his observed drug transactions, and his evasive behavior. The court also determined that the jury instructions were not misleading, the evidentiary rulings were within the court's discretion, and there was no substantial interference with the witness's decision to testify. Additionally, the court found that the prosecution's closing remarks did not constitute plain error or prosecutorial misconduct. View "United States v. Fairley" on Justia Law

BlueCross BlueShield of Tennessee (BlueCross) is an insurer and fiduciary for an ERISA-governed group health insurance plan. A plan member in New Hampshire sought coverage for fertility treatments, which BlueCross denied as the plan did not cover such treatments. The Commissioner of the New Hampshire Insurance Department initiated an enforcement action against BlueCross, alleging that the denial violated New Hampshire law, which mandates coverage for fertility treatments. BlueCross sought to enjoin the state regulatory action, arguing it conflicted with its fiduciary duties under ERISA.The United States District Court for the Eastern District of Tennessee denied BlueCross's request for relief and granted summary judgment to the Commissioner. The court found that the Commissioner’s enforcement action was against BlueCross in its capacity as an insurer, not as a fiduciary, and thus was permissible under ERISA’s saving clause, which allows state insurance regulations to apply to insurers.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The Sixth Circuit held that the Commissioner’s action was indeed against BlueCross as an insurer, aiming to enforce New Hampshire’s insurance laws. The court noted that ERISA’s saving clause permits such state actions and that BlueCross could not use its fiduciary duties under ERISA to evade state insurance regulations. The court also referenced the Supreme Court’s decision in UNUM Life Insurance Co. of America v. Ward, which established that state insurance regulations are not preempted by ERISA when applied to insurers. Thus, the Sixth Circuit concluded that ERISA did not shield BlueCross from the New Hampshire regulatory action. View "BlueCross BlueShield of Tennessee v. Nicolopoulos" on Justia Law

Debra Tucker applied for disability insurance benefits under Title II of the Social Security Act in 2018. After multiple denials at the administrative level, she appealed to the federal district court. In 2023, the district court reversed the final administrative decision of the Commissioner of Social Security, remanding Tucker’s claim for further administrative proceedings. The district court awarded Tucker’s attorney $7,500 in attorney’s fees under the Equal Access to Justice Act (EAJA), along with $402 in costs. Tucker’s attorney had a contingency-fee agreement for twenty-five percent of any past-due benefits awarded. In August 2024, an administrative law judge found Tucker disabled and granted her monthly disability benefits retroactive to February 2018, totaling $124,821.70 in past-due benefits.The district court granted in part and denied in part the attorney’s motion for $31,205.43 in fees under 42 U.S.C. § 406(b), awarding $17,400 instead. The court found the requested fee excessive, amounting to a windfall, and set an imputed hourly rate of $500. The attorney’s motion for reconsideration, reducing the fee request to $22,620, was denied. The attorney appealed, seeking the full $31,205.43.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court found that the district court properly started with the contingency-fee agreement and then tested it for reasonableness, considering the effective hourly rate and other factors. The district court did not misapply the law by comparing the effective hourly rate to the EAJA rate and the attorney’s ordinary rate. The appellate court affirmed the district court’s decision, concluding that it acted within its discretion in reducing the fee to avoid a windfall. View "Tucker v. Commissioner of Social Security" on Justia Law

Plaintiffs, current and former employees of DENSO International America, Inc., alleged that the company's 401(k) Plan overpaid for recordkeeping and administrative services, breaching the fiduciary duty of prudence under the Employee Retirement Income Security Act of 1974 (ERISA). They claimed that the Plan's fiduciaries failed to use their significant bargaining power to negotiate lower fees, resulting in excessive costs compared to similar plans.The United States District Court for the Eastern District of Michigan dismissed the plaintiffs' complaint, stating that it failed to provide the necessary "context specific" facts to support an ERISA overpayment-for-recordkeeping-services claim. The court found that the plaintiffs did not sufficiently detail the types and quality of services provided to the Plan compared to those provided to other plans.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit held that the plaintiffs did not plausibly allege a breach of the duty of prudence because they failed to provide specific details about the services received by the Plan and how they compared to those received by the comparator plans. The court emphasized that a meaningful benchmark is necessary to evaluate whether the fees were excessive relative to the services rendered. The court also noted that general allegations about the fungibility of recordkeeping services and the bargaining power of mega plans were insufficient without specific context.The Sixth Circuit concluded that the plaintiffs' complaint did not meet the required pleading standards and affirmed the district court's dismissal of the case. View "England v. DENSO International America, Inc." on Justia Law

The case involves the Public Interest Legal Foundation (PILF) filing a two-count complaint against Jocelyn Benson, the Michigan Secretary of State, alleging non-compliance with the National Voter Registration Act of 1993 (NVRA). PILF claimed that Michigan failed to conduct proper maintenance of voter registration lists by not removing deceased registrants and did not allow inspection of public records related to voter rolls. PILF's requests for records and subsequent correspondence with the Secretary of State's office did not yield the desired information, leading to the lawsuit.The United States District Court for the Western District of Michigan granted summary judgment in favor of Secretary Benson. The court found that Michigan's efforts to maintain voter registration lists, including using state and federal death records and collaborating with the Electronic Registration Information Center (ERIC), constituted a reasonable effort under the NVRA. The court also found that PILF's claim regarding the failure to allow inspection of records was moot.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's summary judgment, agreeing that Michigan's program for removing deceased registrants was reasonable under the NVRA. The court noted that the NVRA requires a reasonable effort, not a perfect one, and that Michigan's multi-layered approach met this standard. The court also found that PILF lacked standing to assert its claim regarding the inspection of records, as it failed to demonstrate concrete downstream consequences from the alleged NVRA violation.In conclusion, the Sixth Circuit affirmed the district court's judgment, holding that Michigan's efforts to maintain accurate voter registration lists were reasonable and that PILF did not have standing to pursue its claim regarding the inspection of records. View "Public Interest Legal Foundation v. Benson" on Justia Law

Several hundred children in Benton Harbor, Michigan, suffered from elevated lead levels in their blood after drinking lead-contaminated water from the city’s public water system for three years. Plaintiffs, represented by their guardians, filed a lawsuit against various state and city officials, as well as two engineering firms, alleging that these parties failed to mitigate the lead-water crisis and misled the public about the dangers of the drinking water. The claims included substantive-due-process and state-created-danger claims under 42 U.S.C. § 1983, as well as state-law negligence claims.The U.S. District Court for the Western District of Michigan dismissed the complaint in full. The court found that the plaintiffs did not plausibly allege a violation of their constitutional rights and declined to exercise supplemental jurisdiction over the state-law claims. Plaintiffs appealed the dismissal of their federal claims against the city and state officials and the state-law claims against one of the engineering firms.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the dismissal of the claims against the state officials, finding that the plaintiffs did not plausibly allege that these officials acted with deliberate indifference. However, the court reversed the dismissal of the claims against the city officials and the City of Benton Harbor, finding that the plaintiffs plausibly alleged that these officials misled the public about the safety of the water, thereby causing the plaintiffs to drink contaminated water. The court also reversed the district court’s declination of supplemental jurisdiction over the state-law claims against the engineering firm and remanded the case for further proceedings. The court affirmed the district court’s denial of leave to amend the complaint. View "Mitchell v. City of Benton Harbor" on Justia Law