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

The plaintiff, a magistrate in the domestic-relations division of a county court, declared her candidacy for a judicial seat alongside a fellow magistrate, who was also a court administrator. During her campaign, the plaintiff distributed literature that criticized her opponent’s work schedule and duties, suggesting that the opponent performed trivial administrative tasks and questioning her competence based on personal circumstances. These campaign materials were perceived by the administrative judge as undermining the integrity of the court and casting both the court and its staff in an unfavorable light. After the plaintiff lost the primary election, the administrative judge terminated her employment as a magistrate.Prior to this appeal, the United States District Court for the Southern District of Ohio dismissed the plaintiff’s suit brought under 42 U.S.C. § 1983, which alleged a violation of her First Amendment free-speech rights. The district court ruled that the court itself was not a legally cognizable entity subject to suit, that sovereign immunity barred claims for money damages against the administrative judge in her official capacity, and that the plaintiff failed to state a plausible free-speech claim against the administrative judge. The plaintiff appealed only the dismissal of her free-speech claim.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. It held that, because the plaintiff occupied a confidential or policymaking position and her campaign speech addressed matters related to court policy and politics in a manner that undermined the loyalty and efficient functioning required by her employer, her termination did not violate the First Amendment. The court affirmed the district court’s judgment, finding that the balancing test usually applied to public employee speech was unnecessary under these circumstances. The court also rejected the plaintiff’s arguments regarding insubordination, the scope of judicial candidate speech protections, and the applicability of strict scrutiny. View "Gaines v. Cross" on Justia Law

Dr. Lawrence Sherman, a physician, was employed one day per week at Tranquility Wellness Center in Southeastern Michigan, a clinic operated by individuals later convicted for their roles in an illegal prescription scheme. The clinic accepted only cash, did not bill insurance, and routinely provided opioid prescriptions, often based on questionable or fake medical records. Dr. Sherman prescribed large quantities of Schedule II controlled substances, sometimes without adequate patient evaluation or verification of medical histories, and was paid per prescription. After an investigation, Sherman was indicted for conspiracy to possess with intent to distribute and to distribute controlled substances, along with multiple counts of unlawful distribution.In the United States District Court for the Eastern District of Michigan, Sherman went to trial while his co-defendants pleaded guilty and testified against him. The jury found Sherman guilty on all counts, and he was sentenced to 144 months in prison. Sherman subsequently moved for a judgment of acquittal and a new trial, both of which the district court denied.The United States Court of Appeals for the Sixth Circuit reviewed Sherman’s conviction and the denial of his post-trial motions. The court held that sufficient evidence supported the convictions, as a rational jury could find Sherman knowingly issued unauthorized prescriptions based on circumstantial evidence, including expert testimony on deviations from standard medical practice. The appellate court also found no reversible error in the district court’s jury instructions, evidentiary rulings, admission of summary charts, or handling of alleged judicial bias. Any errors identified were deemed harmless in light of overwhelming evidence. The court affirmed both Sherman’s conviction and the denial of his motion for a new trial. View "United States v. Sherman" on Justia Law

Two Ohio homeowners discovered that their personal information, including their names, addresses, and property details, appeared in paid reports on a real estate research website operated by a company. The website allows users to search for property information by address or owner name and provides one free report per user, with additional reports available for purchase. The homeowners, without having consented to the use of their information, filed a class action lawsuit on behalf of similarly situated individuals, alleging that the company violated their rights of publicity under both Ohio statute and common law by using their identities for commercial gain.The United States District Court for the Northern District of Ohio reviewed the case after the company moved to dismiss for failure to state a claim. The district court granted the motion and dismissed the complaint with prejudice, finding that the plaintiffs had not adequately alleged that their identities possessed independent commercial value—a necessary element of a right of publicity claim under Ohio law.On appeal, the United States Court of Appeals for the Sixth Circuit conducted a de novo review. It affirmed the district court's dismissal, holding that the plaintiffs failed to plead facts showing that their names or identities had any commercial value, as required by both Ohio’s statutory and common law right of publicity. The court reasoned that simply being used in a commercial context does not satisfy the commercial value requirement, relying on both prior circuit precedent and Ohio state court decisions. The court also declined to certify a question of law to the Ohio Supreme Court, concluding that Ohio law on this issue was sufficiently settled. The judgment of the district court was affirmed. View "LaFleur v. Yardi Systems, Inc." on Justia Law

The plaintiff was employed as a legal assistant and later a paralegal in a law firm’s Liquor Group, initially at one firm and then at another firm, Adams and Reese, LLP, after her group switched employers. She alleged that a supervisor, who moved with the group, persistently directed sexualized comments and jokes at her in the workplace, which included derogatory remarks, inappropriate suggestions, and comments about her appearance and personal life. She also claimed that after her employer changed her work schedule, she experienced difficulties related to her disabilities and was subsequently terminated when she was unable to comply with the new attendance requirements. She brought claims of sexual harassment and violations of the Americans with Disabilities Act (ADA).The United States District Court for the Middle District of Tennessee reviewed the employer’s motions to dismiss the sexual harassment claim and to compel arbitration of the ADA claims, based on an arbitration agreement between the parties. The district court denied both motions, holding that the plaintiff sufficiently stated a plausible sexual harassment claim under applicable standards and that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) barred enforcement of the arbitration agreement as to her entire case, not just the sexual harassment claim.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court held that the plaintiff’s complaint plausibly alleged pervasive sexual harassment sufficient to survive a motion to dismiss. It further determined that the EFAA renders predispute arbitration agreements unenforceable with respect to an entire “case” relating to a sexual harassment dispute, not just the specific sexual harassment claim. Therefore, the arbitration agreement could not be enforced as to any of the plaintiff’s claims in this action. The disposition was to affirm and remand for further proceedings. View "Bruce v. Adams & Reese, LLP" on Justia Law

In this case, a police officer obtained a search warrant for a Detroit home based on information from a confidential informant and the officer’s own surveillance, which allegedly observed suspected drug transactions. The search led to the discovery of a large quantity of cocaine and firearms in a laundry hamper at the residence, along with personal mail addressed to the plaintiff, Darell Chancellor. Chancellor was later arrested and prosecuted for narcotics offenses, resulting in a conviction and a prison sentence of over fourteen years. Several years later, after a review by a Conviction Integrity Unit found the officer’s reported claims uncorroborated or refuted, Chancellor’s conviction was vacated by a state court order, and he was released from prison.Chancellor subsequently filed a federal lawsuit against the officer and the City, alleging violations of his federal and state rights, including claims of false arrest, false imprisonment, malicious prosecution, and a due process claim under Brady v. Maryland for failing to disclose exculpatory evidence. The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the officer, finding qualified immunity applied to the federal claims, no material issue of fact supported the Brady claim, and governmental immunity barred the state law claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court held that Chancellor had not presented sufficient evidence to show that the officer deliberately or recklessly lied in the search warrant affidavit, as required to overcome qualified immunity. The court also ruled that Chancellor’s due process claim failed because he did not show that the officer suppressed exculpatory evidence. Finally, the court found Chancellor’s state law claims were either inadequately argued or otherwise failed under Michigan law. The disposition by the Sixth Circuit was to affirm the district court’s grant of summary judgment. View "Chancellor v. Geelhood" on Justia Law

A commercial trucking business owner, who is white, learned about a $25,000 grant program administered by two insurance companies in partnership with another company. The program offered grants to ten small businesses to help them purchase commercial vehicles but was limited to black-owned businesses. After receiving an email invitation to apply, the business owner began the online application but stopped and did not submit it upon realizing that only black-owned businesses were eligible. He later alleged that he would have otherwise applied and met all requirements except for the race-based criterion.Following the application deadline, the business owner and his company filed a putative class action in the United States District Court for the Northern District of Ohio, claiming that the grant program’s racial eligibility requirement violated 42 U.S.C. § 1981 by denying them the opportunity to enter into two contracts: one at the application stage and one at the grant award stage. The complaint sought damages and injunctive relief. The district court dismissed the case for lack of subject-matter jurisdiction, concluding that the plaintiffs lacked standing because they had not suffered a cognizable injury caused by the defendants’ conduct.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 the plaintiffs failed the causation requirement for standing because the business owner chose not to submit the application, resulting in any alleged injury being self-inflicted rather than fairly traceable to the defendants’ actions. The court clarified that the judgment was without prejudice and affirmed the district court’s dismissal for lack of subject-matter jurisdiction. View "Roberts v. Progressive Preferred Insurance Co." on Justia Law

Three individuals were prosecuted for their roles in a murder-for-hire scheme that resulted in the deaths of Holly Williams and William Lanway in Nashville. After one of the defendants, Maund, was blackmailed by Lanway following an affair with Williams, he hired Peled to address the situation. Peled then recruited Brockway, Carey, and others to surveil the victims, ultimately leading to their murders in March 2020. Substantial evidence was presented at trial, including recorded conversations, testimony from co-conspirators, financial records, and surveillance footage linking the defendants to the crimes.The United States District Court for the Middle District of Tennessee presided over the joint trial. The jury convicted all three defendants on various counts, including murder-for-hire conspiracy, and convicted Brockway and Carey on kidnapping-related charges. After the verdict, the district court discovered a critical error: the jury had received ten unadmitted exhibits—including recordings and transcripts not presented at trial—and had not received three admitted exhibits. Notably, among the unadmitted exhibits were statements concerning Carey’s knowledge of the crimes that had been excluded at trial. Following a post-verdict hearing, the district court concluded that this error was structural and required a new trial for all defendants, reasoning that the effects of the error were too difficult to measure.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of a new trial. The appellate court held that the erroneous jury exposure to unadmitted exhibits was not a structural error and was subject to harmless-error analysis. Applying the strictest harmless-error standard, the court found the error harmless beyond a reasonable doubt given the overwhelming evidence of guilt and the minimal prejudice to the defendants. The Sixth Circuit reversed the district court’s order granting a new trial and remanded for further proceedings. View "United States v. Maund" on Justia Law

A tornado struck Tennessee, damaging two properties owned by a church that held property insurance with an insurer. The church filed a claim, and the insurer made a payment, but the church alleged that the insurer improperly calculated the amount by subtracting depreciation for non-material costs (such as labor) from the "actual cash value" (ACV) payment, leading to a lower payout. The insurance policy did not specify whether labor should be depreciated. The church then brought a putative class action, asserting similar claims under the laws of ten states, seeking class certification for policyholders who received reduced ACV payments because of the insurer’s practice.The United States District Court for the Middle District of Tennessee addressed several motions. It rejected the insurer’s argument that the church lacked Article III standing to assert claims under other states' laws, and denied the insurer’s motion for judgment on the pleadings as to Texas law. When considering class certification, the district court found the plaintiff satisfied Rule 23(a)’s requirements but limited class certification to four states (Arizona, California, Illinois, and Tennessee), citing unsettled law in the remaining six states. The court reasoned that the uncertain nature of laws in Kentucky, Ohio, Missouri, Mississippi, Texas, and Vermont would make a ten-state class action unwieldy, and thus declined to certify a class for those states.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. It held that the plaintiff had Article III standing to represent the class because the alleged injuries were substantially similar across the proposed class members. The appellate court found that the district court abused its discretion by not conducting an Erie analysis for five of the six excluded states and vacated the class-certification order in part, remanding for further proceedings. However, it affirmed the denial of class certification for Vermont due to insufficient authority on Vermont law. View "Generation Changers Church v. Church Mutual Ins. Co." on Justia Law

The case concerns a life insurance policy that was issued by an insurer to Ewanda Ferguson. After the policy had lapsed for nonpayment, Ewanda applied for reinstatement by submitting an application in which she falsely denied having her driver’s license suspended or being convicted of DUI/DWI in the prior ten years. In reality, Ewanda had two operating-while-impaired convictions and a license revocation within that period. She died in an automobile accident a few months later. The insurer reinstated the policy posthumously and the beneficiary, Elizabeth Ferguson, submitted a claim for the death benefit.Following Ewanda’s death and the submission of the claim, the insurer discovered the misrepresentations in the reinstatement application. Because Ewanda died within the two-year contestability period, the insurer reviewed her application, determined that it would not have reinstated the policy had it known of her true driving history, and rescinded the policy. The insurer then refused to pay the death benefit. Elizabeth Ferguson filed suit in Michigan state court, alleging breach of contract. The insurer removed the case to the United States District Court for the Eastern District of Michigan and counterclaimed to confirm the propriety of rescission. The district court granted summary judgment to the insurer, holding that rescission was proper without balancing the equities, because Ferguson was not an “innocent third party” under Michigan law.On appeal, the United States Court of Appeals for the Sixth Circuit held that, under Michigan law, a life insurance beneficiary who is a third-party beneficiary stands in the shoes of the insured and has no greater rights than the insured would have had. Therefore, the insurer was entitled to rescind the policy based on material misrepresentations made by Ewanda, and the district court was not required to balance the equities before ordering rescission. The Sixth Circuit affirmed the district court’s judgment. View "Ferguson v. MetLife Investors USA Insurance Co." on Justia Law

Federal and state authorities initially suspected Luz Jiminez of involvement in a drug-trafficking organization based in Phoenix, Arizona. Investigators obtained a wiretap order to intercept communications from Jiminez and her associates. Through intercepted calls, they learned Jiminez planned to pick up luggage for someone named “Rondo,” later identified as Liggins. Using a “check and miss” scheme, Liggins sent a bag containing nearly $37,000 from Detroit to Phoenix, which Jiminez retrieved but abandoned after noticing surveillance. A police dog alerted to drugs, and a warrant led to the discovery of the money. Separately, Detroit authorities arrested DeHaven Murphy, who possessed heroin and later implicated Liggins. Murphy arranged recorded calls with Liggins, but Detroit officers testified their investigation was independent of the Arizona wiretap.The United States District Court for the Eastern District of Michigan presided over Liggins’s trial, where a jury convicted him on drug charges. The United States Court of Appeals for the Sixth Circuit vacated the conviction due to judicial bias and remanded for a new trial. On remand, Liggins moved to suppress evidence derived from the Arizona wiretap, arguing violations of federal wiretap laws. The district court denied the motion, finding Liggins lacked standing as an “aggrieved person” under Title III and that the Detroit evidence was untainted by the Arizona wiretap. Liggins entered a conditional guilty plea to preserve his right to appeal.The United States Court of Appeals for the Sixth Circuit reviewed whether Liggins qualified as an “aggrieved person” entitled to move for suppression under Title III. The court held that regardless of the interpretation, Liggins was not an “aggrieved person”: he did not participate in intercepted calls, the calls did not use his property, and he was not named or targeted in the wiretap application. The court affirmed the district court’s denial of the motion to suppress. View "United States v. Liggins" on Justia Law