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

This case concerns a challenge to new regulations issued by the Centers for Disease Control and Prevention (CDC) regarding the importation of dogs into the United States. The CDC, responding to incidents in which rabid dogs entered the country using fraudulent paperwork, amended its regulations to require that all imported dogs have a microchip, be at least six months old, and that importers submit a Dog Importation Form. These measures were intended to ensure the identity of the dogs, their vaccination status, and prevent the introduction of rabies, which remains a risk in other countries.Plaintiffs, consisting of a U.S. hunter, a Canadian dog breeder, and a hunting organization, filed suit in the United States District Court for the Western District of Michigan. They argued that the age and microchip requirements exceeded the CDC's statutory authority and were arbitrary and capricious. They sought a preliminary injunction to prevent enforcement of these requirements, particularly as applied to dogs from rabies-free and low-risk countries. The magistrate judge recommended, and the district court agreed, that the plaintiffs failed to show a likelihood of success on the merits, and denied the injunction. Plaintiffs then appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of the preliminary injunction. The appellate court concluded that the plaintiffs were unlikely to succeed on the merits of their claims. The court held that the age and microchip requirements were likely within the CDC’s statutory authority under 42 U.S.C. § 264, as they constitute inspections or other necessary measures to prevent the introduction of communicable diseases. The court also determined that the rulemaking was not arbitrary or capricious. Accordingly, the Sixth Circuit affirmed the district court’s denial of the preliminary injunction. View "U.S. Sportsmen's Alliance Found. v. Centers for Disease Control and Prevention" on Justia Law

A global manufacturer of automotive clutches entered into a contract with a components manufacturer to supply levers for use in the clutches. The levers were to be manufactured strictly according to the specifications provided, with no design responsibility on the supplier. Between 2017 and 2018, several of the supplied levers broke, causing clutch failures in the field. The buyer communicated with the supplier about these issues through emails, reports, and meetings, and the parties disputed whether these communications constituted notice of breach. The buyer eventually filed suit for breach of contract and breach of express and implied warranties.The United States District Court for the Northern District of Ohio denied the supplier’s motions for judgment on the pleadings and summary judgment, holding that there were sufficient allegations and factual disputes regarding whether the buyer had given adequate notice of breach as required under Ohio law. The case proceeded to trial, where the jury found in favor of the buyer on all claims and awarded significant damages. The supplier appealed, arguing that the Ohio statute requiring pre-suit notice of breach barred the buyer’s claims, and that errors in witness testimony and jury instructions warranted a new trial.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The appellate court held that under Ohio Revised Code § 1302.65(C)(1), interpreted through Ohio Supreme Court precedent, notice of breach does not require explicit language alleging breach, but rather communication sufficient to alert the seller that there is a problem. The court found the evidence supported the jury’s verdict, the jury instructions properly reflected Ohio law, and there was no reversible error in the admission of witness testimony. The judgment in favor of the buyer was affirmed. View "Eaton Corp. v. Angstrom Auto. Group, LLC" on Justia Law

During a contentious divorce and custody dispute, Amanda Hovanec, who had returned to Ohio from South Africa with her children, conspired with Anthony Theodorou, her romantic partner, to kill her husband, T.H. After failed attempts to hire hitmen in South Africa, Theodorou, at Hovanec’s direction, obtained and shipped etorphine, a dangerous animal tranquilizer, to the United States. Hovanec ultimately used the drug to fatally inject T.H. at her mother Anita Green’s home. Green assisted after the murder by helping to select a burial site, driving the others to dig a grave, and later transporting them and the body for burial. The group also undertook efforts to conceal the crime, including disposing of T.H.’s belongings and misleading authorities. All three were arrested after an investigation revealed dashcam footage of the crime.In the United States District Court for the Northern District of Ohio, Hovanec pleaded guilty to multiple controlled-substance offenses resulting in death, and Green pleaded guilty to being an accessory after the fact. Hovanec received a 480-month sentence; Green received 121 months and was ordered to pay restitution for psychological care for T.H.’s and Hovanec’s children. Both defendants appealed their sentences and, in Green’s case, the restitution order.The United States Court of Appeals for the Sixth Circuit affirmed the sentences for both Hovanec and Green. The appellate court upheld the denial of a sentencing reduction for Green based on her lack of candor regarding knowledge of the murder plan. The court also affirmed the sentencing enhancements for Hovanec’s leadership role and obstruction of justice. However, the court reversed the restitution order against Green, holding that under federal law, restitution for psychological care requires evidence of bodily injury, defined as physical harm or physical manifestations of psychological harm, and remanded for further factual findings on this issue. View "United States v. Green" on Justia Law

An employee at a construction company alleged that he faced repeated harassment at work after revealing that he was bisexual. According to his account, coworkers and a supervisor directed homophobic slurs and derogatory comments at him over several months. The employee reported the harassment to a manager on two occasions, initially without naming the harassers, and later with more details. Eventually, after a particularly hostile exchange, he formally complained to the company’s human resources department, which initiated an investigation. The HR manager interviewed the employee and nine other workers, none of whom corroborated his claims. Nonetheless, the company issued a written warning to the supervisor for inappropriate language, required all employees to review the antidiscrimination policy, and allowed the employee to transfer worksites and take medical leave.After the employee took extended medical leave, the company offered him several alternative work assignments, which he either declined or raised objections to. Ultimately, the company considered his refusals as a voluntary resignation and terminated his employment. The employee sued, alleging a hostile work environment and retaliation under Title VII and Michigan law.The United States District Court for the Eastern District of Michigan granted summary judgment to the employer on both claims. It found the company’s actions in response to the harassment allegations were prompt and appropriate, and that the employee failed to show that the termination was pretext for retaliation. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The appellate court held that the employer was not liable for coworker harassment because it took reasonable steps to investigate and address the allegations, and that the employee did not present sufficient evidence of pretext regarding his termination. View "Hamm v. Pullman SST, Inc." on Justia Law

A woman was murdered by her neighbor, who had a documented history of violence and mental illness. Over the two years preceding her death, the Sheriff’s Office in the relevant county received multiple reports about the neighbor’s threatening behavior, particularly toward women, but allegedly failed to act appropriately. The decedent’s estate claimed that the Sheriff’s Office systematically provided inferior protective services in response to threats against women compared to men, citing examples involving both the decedent and other women who reported threats. The estate asserted claims under the Equal Protection Clause and Michigan’s Elliott-Larsen Civil Rights Act.The United States District Court for the Western District of Michigan dismissed the federal claims for lack of standing and for failure to state a claim, and declined to exercise supplemental jurisdiction over the state-law claims. The estate appealed, challenging only the dismissal of its federal equal protection claims.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the estate lacked standing to bring the federal equal protection claims because the complaint did not allege that the decedent herself was personally denied equal protection by the Sheriff’s Office. Instead, the complaint described discriminatory treatment experienced by other women. The court explained that equal protection claims must be based on the plaintiff’s own legal rights, not those of third parties, and the estate did not qualify for the limited exception allowing third-party standing. As a result, the court affirmed the district court’s dismissal of the complaint in its entirety. View "Henry v. Blank" on Justia Law

The plaintiff applied for disability benefits from the Social Security Administration (SSA) but was denied at the agency level. She then sought judicial review in the United States District Court for the Northern District of Ohio. After the Commissioner of Social Security reviewed the case further, the Commissioner moved to remand the matter to the Administrative Law Judge (ALJ) for additional proceedings, specifically for further articulation regarding the persuasiveness of the evidence and further consideration of medical opinions. The Commissioner did not argue that the ALJ committed reversible error. The plaintiff agreed to a remand but requested that the court issue instructions to award her benefits outright.The district court granted the Commissioner’s motion for remand, reasoning that factual disputes remained and that it was not prepared to award benefits. The court remanded the case to the SSA for further consideration without affirming, modifying, or reversing the ALJ’s decision, and without expressly finding reversible error or making the specific predicate findings required for a remand under Sentence Six of 42 U.S.C. § 405(g). The plaintiff appealed the district court’s order.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that a district court may not remand a Social Security case under Sentence Four of 42 U.S.C. § 405(g) without explicitly affirming, modifying, or reversing the decision of the ALJ. The appellate court found that the district court’s order failed to comply with the requirements of either Sentence Four or Sentence Six and that district courts do not have inherent authority to issue other types of remand orders in Social Security cases. The Sixth Circuit therefore vacated the district court’s order and remanded the matter for further proceedings consistent with the opinion. View "Follen v. Commissioner of Social Security" on Justia Law

A man was convicted in Michigan of assault with intent to murder and various firearm offenses following a shooting incident. The case arose from a dispute involving the vandalism of homes, which led to a confrontation between the families of the victim and the accused. During the incident, several family members of the victim identified the accused as the shooter in photo lineups and at trial. The prosecution’s case relied heavily on these identifications and a recorded prison call, while the defense presented testimony from the accused’s sister, who suggested another individual committed the shooting. No physical evidence linked the accused to the crime.After his conviction, the defendant appealed to the Michigan Court of Appeals, arguing, among other things, that his trial counsel was ineffective for failing to call certain witnesses who could have provided an alibi or implicated another person. The appellate court affirmed his conviction, and the Michigan Supreme Court denied leave to appeal. The defendant then moved for post-conviction relief in Michigan state court, raising the same ineffective assistance claim, but the court found counsel’s decisions were reasonable and denied relief. Both the Michigan Court of Appeals and Supreme Court denied further review.The defendant subsequently filed a habeas petition in the United States District Court for the Eastern District of Michigan. The district court rejected the state’s timeliness objection and conditionally granted habeas relief on ineffective assistance grounds. On appeal, the United States Court of Appeals for the Sixth Circuit held that the habeas petition was untimely under the Antiterrorism and Effective Death Penalty Act (AEDPA), as the defendant’s state post-conviction motion did not toll the limitations period under Michigan law, and equitable tolling did not apply. The Sixth Circuit also found that, even if timely, the ineffective assistance claim failed on the merits. The court reversed the district court’s grant of habeas relief. View "Borns v. Chrisman" on Justia Law

Thomas O’Hara filed for Chapter 13 bankruptcy in early 2024. When the United States Trustee sought to dismiss his case, the bankruptcy court held a hearing and indicated it would convert the case to Chapter 7, unless O’Hara exercised his right to voluntarily dismiss under 11 U.S.C. § 1307(b) before the conversion order was entered. O’Hara did not file a motion to dismiss until after the bankruptcy court entered an order converting the case. His subsequent attempt to dismiss under § 1307(b) was denied, as was his later motion under Rule 60(b), in which he argued his delay should be excused as neglect and that his right to dismiss was circumvented.The United States District Court for the Western District of Michigan reviewed the bankruptcy court’s orders. The district court concluded that O’Hara’s appeals regarding the conversion and denial of dismissal were untimely, except for his timely appeal of the bankruptcy court’s denial of his Rule 60(b) motion. The district court affirmed the bankruptcy court, finding O’Hara’s Rule 60(b) motion meritless, as the case had already been converted before his dismissal motion was filed, and found no excusable neglect or extraordinary circumstances.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s affirmance. It held that its jurisdiction was limited to review of the August 7 order denying Rule 60(b) relief, as only that appeal was timely. The Sixth Circuit concluded that the bankruptcy court did not abuse its discretion in denying Rule 60(b) relief, because O’Hara’s failure to seek dismissal prior to conversion was a strategic decision, not excusable neglect, and his right to dismiss under § 1307(b) ceased once the case was converted. The court affirmed the district court’s decision and remanded for further proceedings. View "O'Hara v. Vara" on Justia Law

The case involves a defendant who was convicted by a jury of aiding and abetting kidnapping after an incident in Detroit. The events began when the defendant was shot during a confrontation involving rival gang members, after which the victim was taken by the defendant’s associates for interrogation. The victim was confined, threatened, and beaten at the defendant’s home, with parts of the incident recorded and later shared in an Instagram group chat. After these events, the victim was driven around, further assaulted, and eventually released.Prior to this appeal, the United States District Court for the Eastern District of Michigan oversaw the trial. The court denied the defendant’s motions to suppress evidence obtained from social media accounts, motions to exclude alleged co-conspirator statements, and ruled partially in favor of the government’s effort to limit cross-examination of the victim. After a weeklong trial, the jury acquitted the defendant of conspiracy but found him guilty of aiding and abetting kidnapping. The district court sentenced him to 198 months in prison and imposed several special conditions of supervised release, some of which were only included in the written judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. It affirmed the district court on four grounds: the denial of suppression motions, the admission of co-conspirator statements, the limitation on cross-examination, and the sufficiency of the evidence for conviction. The appellate court held that the defendant’s constitutional and evidentiary challenges failed. However, it found a discrepancy between the oral pronouncement of sentence and the written judgment regarding two special conditions of supervised release. The court remanded the case to the district court to resolve this discrepancy and, if needed, to consider the constitutional challenges to those conditions. View "United States v. Blake" on Justia Law

Brandie Nicole Appleton, along with an accomplice, burglarized a Tennessee pharmacy, stealing substantial quantities of controlled substances, firearm parts, and ammunition. After fleeing the scene and attempting to evade law enforcement, Appleton was apprehended, and the stolen items were recovered from her vehicle. Appleton subsequently pleaded guilty to possessing controlled substances with intent to distribute and possessing stolen ammunition. As part of her plea agreement, she waived her right to appeal any sentence within or below the Sentencing Guidelines range.The United States District Court for the Middle District of Tennessee determined Appleton’s Guidelines range to be 41 to 51 months of imprisonment but, noting her progress in overcoming addiction and her personal circumstances, sentenced her to five years of probation. The district court warned her of serious consequences if she violated any probation conditions. Approximately six weeks later, Appleton was arrested for possessing an unprescribed controlled substance, which constituted a violation of her probation. After a revocation hearing, the district court sentenced her to 44 months of imprisonment, within the original Guidelines range.The United States Court of Appeals for the Sixth Circuit reviewed Appleton’s appeal, in which she argued that the district court erred in imposing her sentence after revoking her probation. The government contended that her appeal was barred by the waiver in her plea agreement. The Sixth Circuit held that Appleton’s appeal waiver applied to any sentence within the Guidelines range, including one imposed after probation revocation for the same underlying offense. The court concluded that the waiver was knowingly and voluntarily made, encompassed her present claims, and did not fall under any exceptions. Therefore, the court dismissed her appeal. View "United States v. Appleton" on Justia Law