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

On the evening of Black Friday in 2021, two employees at a T-Mobile store in Columbus, Ohio were robbed at gunpoint by a masked individual who forced them into a back room, demanded phones and money, and sprayed them with mace before fleeing. Unbeknownst to the robber, a bait phone with a GPS tracker was included among the stolen items, allowing police to quickly locate and apprehend him after a high-speed chase. The suspect, Kevin Daniels, was arrested and, after waiving his Miranda rights during interrogation, admitted to the crime. A search of his vehicle found the stolen goods, a gun, and the disguise used in the robbery.The United States District Court for the Southern District of Ohio presided over Daniels’s trial. He was indicted on three counts: Hobbs Act robbery, brandishing a firearm during a crime of violence, and felon-in-possession of a firearm. After a jury convicted him on all counts, the district court calculated a sentencing guidelines range of 78 to 97 months for the robbery and possession offenses, and imposed the mandatory minimum 7-year sentence for the firearm offense, resulting in a total sentence of 181 months. Daniels raised various pretrial and sentencing challenges, including suppression of statements, issues with counsel, discovery violations, and objections to guideline enhancements.The United States Court of Appeals for the Sixth Circuit reviewed Daniels’s appeal, which included constitutional, evidentiary, instructional, and sentencing claims. The court held that Daniels knowingly and voluntarily waived his Miranda rights, that the district court did not abuse its discretion in denying substitution of counsel, and that there was no reversible error related to discovery or jury instructions. The court also affirmed the application of the physical-restraint and bodily-injury enhancements, and found no error in the calculation of Daniels’s criminal history score. The judgment of the district court was affirmed. View "United States v. Daniels" on Justia Law

Nationwide Recovery, a towing company, held a permit with the City of Detroit to recover stolen vehicles, which provided significant economic benefits. In July 2017, the Detroit Police Department suspected that a Nationwide tow operator was colluding with car-theft gangs by bribing them for tips on stolen vehicle locations. These suspicions led to the immediate suspension of Nationwide’s towing permit without a hearing. Subsequent investigations uncovered evidence suggesting that a Nationwide driver communicated with, and likely paid, known car thieves for information, allowing for rapid recovery of stolen vehicles. Further audits revealed that Nationwide had routinely charged excessive fees beyond the amounts permitted by city rules.In response to the suspension, Nationwide and associated plaintiffs filed suit in the United States District Court for the Eastern District of Michigan, alleging a procedural due process violation under 42 U.S.C. § 1983. The district court initially found that the towing permit constituted a property interest and that the lack of a hearing deprived Nationwide of due process. However, after extensive discovery, the district court concluded that, based on after-acquired evidence, Nationwide’s conduct—including collusion with car thieves and fee overcharging—would have justified termination even if a hearing had occurred. Therefore, the court limited Nationwide’s damages to nominal damages and entered judgment for one dollar.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions de novo and for abuse of discretion. The Sixth Circuit affirmed, holding that although the City failed to provide procedural due process, the after-acquired evidence justified permit termination, and thus Nationwide was not entitled to compensatory damages. The court clarified that in procedural due process cases, post-termination evidence may be considered, and where termination would have occurred regardless of the process, only nominal damages are available. The judgment for nominal damages was affirmed. View "Nationwide Recovery, Inc. v. City of Detroit" on Justia Law

In 2020, an activist named Sir Maejor Page created and operated a Facebook page for an organization called Black Lives Matter of Greater Atlanta (BLMGA), which he registered as a nonprofit in Georgia and obtained tax-exempt status. After failing to file required tax forms for three years, BLMGA’s tax-exempt status was revoked, but the organization continued to appear as a nonprofit on Facebook and receive donations. Following the death of George Floyd, donations surged to over $490,000. Page assured donors that the money would support protests and related activities, but he instead used the funds for personal expenses, including luxury items, a house, home renovations, firearms, and hiring a prostitute.The United States District Court for the Northern District of Ohio indicted Page on one count of wire fraud and three counts of money laundering, alleging he defrauded donors by misrepresenting the intended use of their contributions. At trial, Page testified in his defense, but the jury found him guilty on all counts. During sentencing, the district court adopted the U.S. Probation Office’s recommendations, overruling Page’s objections regarding obstruction of justice, loss amount, and number of victims. The court imposed a sentence of 42 months’ imprisonment on each count, to run concurrently, followed by three years of supervised release.The United States Court of Appeals for the Sixth Circuit reviewed Page’s convictions and sentence. The court held that there was sufficient evidence to support the wire fraud and money laundering convictions, finding Page’s misrepresentations induced donations and that the funds were used for personal benefit. The court also upheld the district court’s evidentiary rulings and sentencing enhancements, concluding there was no plain or prejudicial error. Accordingly, the Sixth Circuit affirmed Page’s convictions and sentence. View "United States v. Page" on Justia Law

Investigators from the DEA and Owensboro Police Department began an investigation in September 2021 into suspected methamphetamine trafficking involving Cedric Swanagan and Courtland Reed. Wiretap evidence, corroborated by intercepted communications and witness testimony, linked Swanagan and Reed to multiple drug transactions, including a key February 2022 incident where Reed paid Nicole Toliver for methamphetamine that was found in her car during a traffic stop. Both defendants were ultimately indicted for conspiracy and possession with intent to distribute large quantities of methamphetamine.The United States District Court for the Western District of Kentucky presided over the consolidated trial. Swanagan moved to suppress evidence from the wiretap, arguing the supporting affidavit contained intentional or reckless falsehoods, but the court denied his motion without a Franks hearing, finding no substantial preliminary showing of falsity. At trial, law enforcement officers testified about intercepted calls, interpreting slang and summarizing conversations. The district court managed objections to this testimony, ensuring officers spoke from personal experience and refrained from narrating facts beyond their direct knowledge. Reed was shackled during trial, but the court took steps to conceal this from the jury. After jurors potentially saw defendants in shackles in the courthouse lobby, the court conducted voir dire and found no actual prejudice. Both defendants were convicted, and the court denied motions for acquittal and new trial. Swanagan was sentenced to 360 months based on enhancements for his leadership in the conspiracy and prior convictions; Reed received a 300-month sentence based in part on a prior burglary conviction.The United States Court of Appeals for the Sixth Circuit affirmed the convictions and Swanagan’s sentence, finding no reversible error in evidentiary rulings, jury management, or sufficiency of the evidence. The court vacated Reed’s sentence, holding that his Kentucky burglary conviction did not qualify as a “serious violent felony” for sentence enhancement under 21 U.S.C. §§ 841 and 851, and remanded for resentencing. View "United States v. Reed" on Justia Law

TAJ Graphics Enterprises, LLC, a Michigan limited liability company controlled by Robert Kattula, twice filed for bankruptcy—first in 2003 under Chapter 11, and again in 2009, with the case later converted to Chapter 7. Prime Financial, Inc., an unsecured creditor owned by Aaron Jade, asserted a claim based on unpaid sums from the 2004 bankruptcy plan. Disputes arose over several assets, including rights under assignments, claims in pending litigation, and a significant debt owed by Kattula to TAJ. Ownership and value of these assets, particularly interests under a Memorandum of Understanding (MOU) for a Kentucky landfill, were contested. The bankruptcy estate lacked funds to litigate asset ownership or liquidation.The United States Bankruptcy Court for the Eastern District of Michigan approved a settlement proposed by the Chapter 7 trustee. The settlement involved Kattula waiving certain claims and paying $50,000 to the estate in exchange for ownership of the disputed assets. The IRS, the estate's senior secured creditor, supported the settlement. Prime Financial objected, arguing the trustee failed to maximize the estate’s value and that its own offer to purchase assets for $100,000 was overlooked. The bankruptcy court found Prime Financial’s offer contingent and unworkable, and determined that litigation over asset ownership would be costly and uncertain. The bankruptcy court approved the settlement, citing the estate’s lack of resources, the speculative asset value, and the interests of creditors. The United States District Court for the Eastern District of Michigan affirmed this decision.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's order. The Sixth Circuit held that the bankruptcy court did not abuse its discretion, applying the correct standard for settlement approval and reasonably assessing the merits, complexity, and creditor interests. Prime Financial’s procedural and substantive objections were rejected. View "Prime Financial, Inc. v. Shapiro" on Justia Law

In this case, Ricco Saine was approached by police in a motel parking lot after a BOLO alert indicated he was suspected of narcotics trafficking. Officers, believing the motel was a known drug location, called in a K9 unit, which alerted on Saine’s truck. A subsequent search uncovered a firearm and a small amount of a substance believed to be marijuana, though its identity was not confirmed. Weeks later, officers investigating at Saine’s home discovered additional firearms, some of which had been purchased by Saine’s wife, Tonya, with Saine present. Police later obtained a text exchange between Saine and Tonya, indicating she had his gun in their house.The United States District Court for the Eastern District of Tennessee denied Saine’s motion to suppress the firearm found in his truck, rejecting his argument that the K9’s inability to distinguish between legal hemp and illegal marijuana invalidated probable cause for the search. At trial, the court also admitted the text exchange between Saine and Tonya, overruling Saine’s objections that it constituted inadmissible hearsay and impermissible propensity evidence under Federal Rule of Evidence 404(b). The jury returned guilty verdicts on both counts of unlawful possession of a firearm as a convicted felon.Reviewing the case, the United States Court of Appeals for the Sixth Circuit held that a K9 alert supplies probable cause for a vehicle search, even when the dog cannot distinguish between legal and illegal cannabis, as probable cause depends on probabilities, not certainties. The court also found that the admission of the text exchange was proper, as it was used to show Saine’s knowledge rather than propensity, and any prejudicial effect did not substantially outweigh its probative value. The court affirmed Saine’s conviction. View "United States v. Saine" on Justia Law

HRT Enterprises pursued a takings claim against the City of Detroit after losing a jury verdict in state court in 2005. Subsequently, HRT filed suit in federal court in 2008, alleging a post-2005 violation under 42 U.S.C. § 1983. The United States District Court for the Eastern District of Michigan dismissed the federal action, citing the requirement from Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985), to exhaust state remedies first. HRT then returned to state court, where its claim was dismissed on claim preclusion grounds, a decision affirmed by the Michigan Court of Appeals. After the state court denied compensation, HRT initiated a federal § 1983 action in 2012. The case was stayed when the City filed for bankruptcy, prompting HRT to participate in bankruptcy proceedings to protect its compensation rights. Ultimately, the bankruptcy court excepted HRT’s takings claim from discharge, allowing the federal case to proceed. After two jury trials, the district court entered judgment for HRT in September 2023.Following its success, HRT moved for attorney fees under 42 U.S.C. § 1988, presenting billing records that included work from related state and bankruptcy proceedings. The district court applied a 33% discount to the claimed hours due to commingled and poorly described entries, set an average hourly rate, and awarded $720,486.25, which included expert witness fees. Both parties appealed aspects of the fee award to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit held that the district court erred by concluding it had no discretion to award fees for work performed in the related state-court and bankruptcy proceedings, as such fees are recoverable when the work is necessary to advance the federal litigation. The court also found the district court erred in awarding expert witness fees under § 1988(c) in a § 1983 action, as the statute does not authorize such fees for § 1983 claims. The appellate court vacated the fee award and remanded for recalculation consistent with its opinion. View "HRT Enterprises v. City of Detroit" on Justia Law

HRT Enterprises owned an 11.8-acre parcel adjacent to Detroit’s Coleman A. Young International Airport, with about 20 percent of the property falling within a regulated runway “visibility zone” that restricted development. Over time, the City of Detroit acquired other properties in a nearby area for airport compliance but did not purchase HRT’s. By late 2008, HRT’s property had become vacant and vandalized, and HRT alleged it could no longer use, lease, or sell the property due to City actions and regulatory restrictions.HRT first sued the City in Michigan state court in 2002, alleging inverse condemnation, but the jury found for the City; the Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied leave to appeal. In 2008, HRT sued in federal court, but the United States District Court for the Eastern District of Michigan dismissed the action without prejudice because HRT had not exhausted state remedies. HRT then filed a second state suit in 2009, which was dismissed on res judicata grounds; the Michigan Court of Appeals affirmed. HRT did not seek further review.In 2012, HRT filed the present action in federal court, alleging a de facto taking under 42 U.S.C. § 1983. The district court denied the City’s preclusion arguments, granted summary judgment to HRT on liability, and held that a taking had occurred, leaving the date for the jury. A first jury found the taking occurred in 2009 and awarded $4.25 million; the court ordered remittitur to $2 million, then a second jury, after a new trial, awarded $1.97 million.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings, holding that HRT’s claim was ripe, not barred by claim or issue preclusion, that the district court properly granted summary judgment on liability, and that its remittitur decision was not an abuse of discretion. View "HRT Enterprises v. City of Detroit" on Justia Law

A research scientist who had worked for over a decade at a public university in Ohio coauthored several well-regarded articles during her tenure. After she left the university for a new position, allegations of research misconduct surfaced regarding some of her publications. The university convened an investigative committee, as required by federal regulations due to its receipt of federal funding. The committee found that she had committed research misconduct and recommended barring her from future university employment, retracting or correcting certain articles, and reported its findings to relevant journals and her current employer. The scientist alleged that the committee deviated from standard investigatory procedures, failed to provide exculpatory evidence, and did not require proof of intent or recklessness.The United States District Court for the Southern District of Ohio dismissed her complaint, which had sought equitable relief under federal and state law. The court held that sovereign immunity shielded the university’s Board of Trustees and the officials sued in their official capacities from most claims. It found several claims time-barred and determined that the remaining constitutional claims, including due process and equal protection, failed on the merits. The court declined to exercise supplemental jurisdiction over the state-law claims against individuals in their personal capacities.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The court held that sovereign immunity barred all claims against the Board of Trustees and all state-law claims against the officials in their official capacities. As to the remaining federal due process claims, the court determined that the plaintiff failed to identify a constitutionally protected liberty interest under the stigma-plus doctrine and that the alleged conduct—even if malicious or in violation of confidentiality regulations—did not amount to conscience-shocking behavior under substantive due process standards. View "Pichiorri v. Burghes" on Justia Law

The plaintiff was incarcerated in Tennessee on sentences from multiple convictions. After being granted parole by the Tennessee Board of Parole, he was not released on his effective parole date because county officials filed a detainer warrant, claiming he had not completed his sentence and was required to serve additional time in county jail. The plaintiff remained in custody for over four months beyond his scheduled release date. He and his family attempted to resolve the situation, and he eventually retained counsel, after which the detainer was lifted and he was released.The plaintiff brought suit in the United States District Court for the Western District of Tennessee against the county, several county officials, state officials, and unnamed defendants under 42 U.S.C. § 1983, alleging violations of his rights under the Fourth and Fourteenth Amendments, as well as state law. The county defendants moved to dismiss for failure to state a claim and asserted qualified immunity. The plaintiff voluntarily dismissed his claims against the state defendants. The district court granted the county defendants’ motion to dismiss, holding that there was no liberty interest in release on parole under Tennessee law, that the individual defendants were entitled to qualified immunity, and that no plausible claim was stated against the county under Monell v. Department of Social Services. The court declined to exercise supplemental jurisdiction over the state law claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit held that Tennessee’s statutory scheme does not create a protected liberty interest in parole or in release following a grant of parole. Without such a liberty interest, the plaintiff’s due process claim failed, and the individual defendants were entitled to qualified immunity. The Monell claim against the county also failed in the absence of an underlying constitutional violation. The appellate court affirmed the district court’s refusal to exercise supplemental jurisdiction over the state law claims. The judgment of the district court was affirmed. View "Hester v. Chester County" on Justia Law