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

Clarence Fry was convicted by a jury of the aggravated felony murder of his girlfriend, Tamela Hardison, and was sentenced to death by an Ohio trial court. The conviction and sentence were affirmed by the Ohio courts on direct appeal, and Fry's request for collateral relief was denied. Fry then petitioned for a writ of federal habeas corpus, which the district court denied.The Ohio Supreme Court affirmed Fry's conviction and sentence. The Ohio Court of Appeals denied state collateral relief, and the Ohio Supreme Court declined additional review. Fry filed a habeas petition in federal court, raising 24 grounds for relief. The district court denied his petition and granted a certificate of appealability on five claims: ineffective assistance of trial counsel, trial-court error, and ineffective assistance of appellate counsel.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Fry's trial counsel did not provide ineffective assistance during plea bargaining, as the state court reasonably found no prejudice. The court also held that Fry's counsel did not prevent him from testifying, as the state court's finding that Fry knowingly waived his right to testify was reasonable. Additionally, the court found that Fry's waiver of mitigation evidence was knowing and voluntary, and thus, there was no prejudice from counsel's performance.The court also addressed Fry's claims of trial court error. It held that the trial court did not violate Fry's right to testify by failing to independently inquire about his decision, as there was no Supreme Court precedent requiring such an inquiry. Lastly, the court found that the trial court did not err in accepting Fry's mitigation waiver, as the extensive colloquy showed that Fry's waiver was knowing and voluntary.The Sixth Circuit affirmed the district court's denial of Fry's habeas petition. View "Fry v. Shoop" on Justia Law

Defendant Shefiu A. Hanson, serving a 46-month sentence for wire fraud, appealed the district court’s denial of his motion to reduce his sentence under 18 U.S.C. § 3582(c)(2). Hanson had pled guilty to wire fraud and conspiracy for creating fraudulent bank and email accounts to induce businesses to wire money to his accounts. The total loss to 30 victims was $1,122,805.74. Hanson, with no prior convictions, had a Criminal History Category of I and an Offense Level of 22, resulting in a Guidelines Range of 41 to 51 months. He was sentenced to 46 months in May 2023.Hanson moved for a sentence reduction under the newly created U.S.S.G. § 4C1.1, which applies retroactively. The government opposed, arguing Hanson was ineligible because he caused substantial financial hardship to his victims. The district court agreed, finding Hanson caused substantial financial harm to multiple victims, making him ineligible under U.S.S.G. § 4C1.1(a)(6). The court also concluded that a sentence reduction would not adequately reflect the seriousness of the offense or provide just punishment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not err in determining Hanson was ineligible for a sentence reduction. The court noted that the financial hardship caused by Hanson did not need to fall perfectly within the factors listed in U.S.S.G. § 2B1.1 n.4F, as the list is non-exhaustive. The district court reasonably concluded that the financial hardship to at least one victim was substantial, citing specific examples of individual victims' hardships. The court affirmed the district court’s order denying Hanson’s motion for a sentence reduction. View "United States v. Hanson" on Justia Law

The case involves the Federal Communications Commission's (FCC) 2024 Safeguarding and Securing the Open Internet Order, which reclassified Broadband Internet Service Providers (ISPs) as offering a "telecommunications service" under Title II of the Communications Act, thereby subjecting them to net-neutrality regulations. The FCC's order also classified mobile broadband as a "commercial mobile service" under Title III, imposing similar regulations.Previously, the FCC had fluctuated in its classification of broadband services. In 2015, the FCC classified broadband as a telecommunications service, which the D.C. Circuit upheld under the Chevron doctrine. In 2018, the FCC reversed this classification, treating broadband as an information service, a decision also upheld by the D.C. Circuit. The 2024 order reversed the 2018 decision, reinstating the 2015 classification.The United States Court of Appeals for the Sixth Circuit reviewed the 2024 order. The court held that Broadband ISPs offer an "information service" under 47 U.S.C. § 153(24), not a telecommunications service. The court reasoned that ISPs provide the capability to retrieve and utilize information via telecommunications, which fits the definition of an information service. The court also found that the FCC's interpretation of the statute was inconsistent with its plain language and historical context.Regarding mobile broadband, the court held that it does not qualify as a "commercial mobile service" under 47 U.S.C. § 332(d)(1) because it is not interconnected with the public switched network, which refers to the traditional telephone network using the North American Numbering Plan. Consequently, mobile broadband is classified as a "private mobile service" and is not subject to common-carrier regulation.The Sixth Circuit granted the petitions for review and set aside the FCC's 2024 Safeguarding Order. View "Ohio Telecom Ass'n v. FCC" on Justia Law

Employees of Mercedes-Benz Research and Development North America, Inc. accidentally set fire to a property leased from Airport Boulevard Associates, LLC (ABA) while transferring gasoline between vehicles. ABA's insurer, Pioneer State Mutual Insurance Company, paid ABA for the damages and sought reimbursement from Mercedes and its insurer, Allianz Global Risks US Insurance Company. Unable to resolve the matter, Pioneer filed a lawsuit in federal court.The United States District Court for the Eastern District of Michigan denied Pioneer's motion for summary judgment and granted summary judgment to Mercedes and Allianz. Pioneer appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision regarding Allianz, holding that the No-Fault Act did not apply because the vehicle was exempt from registration and the Allianz policy did not provide property protection insurance. The court also rejected Pioneer's argument for apportionment of recovery between the insurers, as the policies insured different parties and risks.However, the court reversed the district court's decision regarding Mercedes. The court found that Mercedes potentially breached the lease by handling hazardous materials, specifically gasoline, on the property. This breach could allow Pioneer to recover damages despite the lease's waiver-of-subrogation clause. The case was remanded for further proceedings on the claims against Mercedes. View "Pioneer State Mut. Ins. v. HDI Global" on Justia Law

Mario Adams, a defendant with a history of mental health issues, was sentenced to 24 months’ imprisonment for violating the terms of his supervised release. Adams argued that the district court improperly considered his mental health as an aggravating factor in its sentencing determination.In 2014, Adams was charged with being a felon in possession of a firearm. He was initially found incompetent to stand trial due to mental health issues but was later deemed competent and pleaded guilty. He was sentenced to 87 months in prison followed by 36 months of supervised release. After his release in 2020, Adams violated the terms of his supervised release multiple times, including missing drug tests, failing to allow home visits, and committing new state crimes.The district court for the Northern District of Ohio revoked Adams’s supervised release based on these violations and sentenced him to 24 months in prison, an upward variance from the Guidelines range of 8 to 14 months. The court emphasized Adams’s conduct, including his absconding from a halfway house and committing violent crimes, as the basis for the sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court did not improperly rely on Adams’s mental health status as an aggravating factor but rather based its decision on Adams’s conduct and the failure of previous interventions to prevent further offenses. The court concluded that the district court’s sentence was procedurally reasonable and based on permissible factors. View "United States v. Adams" on Justia Law

Miguel Angel Moctezuma-Reyes, a Mexican citizen, entered the United States illegally in 2005 and has since lived in Michigan with his wife, three of his four children, and his niece. His two youngest sons are American citizens, while his wife and daughter lack legal status. Moctezuma-Reyes works in a fence factory, and his daughter is a medical assistant. Together, they support the family financially. The Department of Homeland Security initiated removal proceedings against him in 2018.An Immigration Judge denied Moctezuma-Reyes's application for cancellation of removal, concluding that he did not meet the statutory requirement of demonstrating "exceptional and extremely unusual hardship" to his qualifying relatives. The Board of Immigration Appeals (BIA) affirmed this decision, agreeing that the hardship his family would face did not meet the necessary threshold.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the statutory standard of "exceptional and extremely unusual hardship" requires hardship that is significantly different from or greater than that typically associated with deportation. The court found that the financial and emotional hardships cited by Moctezuma-Reyes, while severe, were not uncommon in deportation cases. The court also noted that his daughter’s employment mitigated some financial hardship and that his sons did not have special needs that would make their situation exceptional. Consequently, the court denied the petition for review, upholding the BIA's decision. View "Moctezuma-Reyes v. Garland" on Justia Law

In Michigan, citizens can amend the state constitution through ballot initiatives without legislative approval. Two state senators and nine state representatives challenged the use of such initiatives to regulate federal elections, arguing it violated the U.S. Constitution's Elections Clause. They sought to prevent Michigan officials from enforcing these amendments.The United States District Court for the Western District of Michigan dismissed the case, ruling that the legislators lacked standing to sue under Civil Rule 12(b)(1). The court found that the plaintiffs did not demonstrate a concrete injury necessary for standing.The United States Court of Appeals for the Sixth Circuit affirmed the district court's dismissal. The appellate court held that the legislators did not have standing because they did not represent the entire legislature or a controlling bloc within it. The court distinguished this case from precedents where entire legislatures or controlling blocs had standing to sue. The court emphasized that individual legislators generally lack standing to assert institutional injuries of the legislature. The court also noted that the legislators had not shown that their votes were nullified by the amendments, as required for standing under relevant Supreme Court precedents.The Sixth Circuit concluded that the legislators' claims did not meet the requirements for standing under Article III of the U.S. Constitution, as they did not suffer a concrete and particularized injury. The court affirmed the district court's dismissal of the case. View "Lindsey v. Whitmer" on Justia Law

Broadgate, Inc. employed an H-1B visa holder who filed a complaint with the Department of Labor’s Wage and Hour Division in February 2018, alleging that Broadgate had not paid him the full wages required by the Immigration and Nationality Act. The Division’s investigation substantiated the claim and found additional violations, including failure to post required workplace notices. Consequently, the Division issued a determination letter in December 2018, finding Broadgate had willfully violated the Act, barring it from the H-1B program for two years, requiring payment of back wages, and assessing a civil penalty.Broadgate sought review before an Administrative Law Judge (ALJ), challenging only the determination regarding the workplace notices. The ALJ agreed with Broadgate, vacating the determination. However, the Department’s Administrative Review Board reversed this decision. On remand, Broadgate argued that the Division exceeded its authority by investigating violations not alleged in the original complaint. The ALJ rejected this argument, and the Review Board and the district court affirmed the Director’s imposition of fines and penalties.The United States Court of Appeals for the Sixth Circuit reviewed the case. Broadgate argued that the District Director lacked authority to issue the determination letter and that the Wage and Hour Division exceeded its authority by investigating the notice violations. The court held that the presumption of regularity applied, meaning the Director’s issuance of the letter was presumptive proof of her authority. The court also found that the Division was entitled to investigate the notice violations discovered during the investigation of the wage complaint. The court affirmed the district court’s judgment, rejecting Broadgate’s arguments. View "Broadgate, Inc v. Su" on Justia Law

During a regulatory inspection on May 9, 2022, Sergeant Jeff Fuller of the Tennessee Highway Patrol stopped a semitrailer. The truck's driver, Euclide Aquino Urraca, exhibited suspicious behavior, and the truck's paperwork and cargo had numerous irregularities. Fuller noticed that the truck's cargo did not match the bill of lading, and the driver and his co-driver were evasive when asked about a heavily taped box found under the bunk. A dog sniff of the truck led to the discovery of 20 kilograms of cocaine.The United States District Court for the Western District of Tennessee held an evidentiary hearing and found that Fuller lacked reasonable suspicion to extend the stop for the dog sniff. The court largely credited Fuller’s testimony but rejected his claim that he believed the box contained narcotics at the time of the search. Consequently, the district court granted Urraca’s motion to suppress the cocaine found in the truck.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the objective facts known to Fuller at the time of the dog sniff justified the investigation. The court held that the combination of the drivers' suspicious behavior, the irregularities in the truck's paperwork and cargo, and the evasive responses about the box provided reasonable suspicion to extend the stop. The court concluded that the dog sniff was permissible, and the subsequent search, which uncovered the cocaine, was lawful under the automobile exception. Therefore, the Sixth Circuit reversed the district court's decision to suppress the evidence. View "United States v. Aquino Urraca" on Justia Law

Jaylin Morton was indicted for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). Morton moved to dismiss the indictment, arguing that the prosecution violated his Second Amendment rights. The district court denied his motion, and Morton conditionally pleaded guilty, retaining the right to appeal the denial of his motion to dismiss.The United States District Court for the Eastern District of Kentucky denied Morton’s motion to dismiss, reasoning that his prior felonies demonstrated that he was a serious and direct threat to public safety. The court concluded that § 922(g)(1) constitutionally applied to him. Morton then appealed the district court’s decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Morton’s criminal history, which included multiple violent offenses such as shooting at his ex-girlfriend and her family, and assaulting his then-girlfriend, demonstrated his dangerousness. The court applied the framework established in United States v. Williams, which allows for disarming individuals who are deemed dangerous based on their criminal history. The court concluded that Morton’s conviction was consistent with the Second Amendment as interpreted in Williams and affirmed the district court’s denial of Morton’s motion to dismiss the indictment. View "United States v. Morton" on Justia Law