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

Wayne County foreclosed on Tonya Bowles's property to satisfy her tax debt and sold it, keeping the surplus proceeds. Bowles filed a § 1983 lawsuit against the county and its treasurer, seeking to recover the surplus and to certify a class of similarly affected former property owners. The district court certified the class without discovery, relying on a similar case's decision.The United States District Court for the Eastern District of Michigan certified the class in 2022. However, subsequent legal developments, including decisions in Fox v. Saginaw County and other cases, highlighted the need for a rigorous analysis under Federal Rule of Civil Procedure 23. These decisions emphasized the necessity of proving, rather than merely alleging, compliance with Rule 23's requirements and questioned the manageability of class actions in takings cases.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court did not conduct the required rigorous analysis of Rule 23's requirements. The court noted that the district court relied on an incomplete record and did not address several critical issues, such as the calculation of damages, potential unique defenses, and the role of third-party lienholders. Additionally, the court highlighted that Bowles's proposed class definition included claims for surplus equity, which are unmanageable in class actions and not permissible under recent case law.The Sixth Circuit vacated the district court's class certification order and remanded the case for further proceedings. The court instructed the district court to conduct a thorough analysis of Rule 23's requirements, considering recent legal developments and ensuring that Bowles can prove numerosity, commonality, typicality, adequacy, and superiority. The court emphasized the need for a complete evidentiary record and a detailed forecast of how the litigation would proceed as a class action. View "Bowles v. Sabree" on Justia Law

Safiya Tayo Tukur Seldon, a native of Nigeria, entered the United States in 1992 using her sister’s passport and a tourist visa. In 1997, she married a U.S. citizen and obtained conditional permanent resident status. However, in 2000, the Immigration and Naturalization Service (INS) concluded that her marriage was a sham and terminated her conditional status, ordering her removal. Seldon did not appear at her initial removal hearing in 2002, leading to an in-absentia removal order. In 2011, she successfully moved to reopen her case, claiming she never received notice of the hearing.An immigration judge (IJ) in Detroit later sustained the charges against her, including marriage fraud, and ordered her removal to Nigeria. Seldon appealed to the Board of Immigration Appeals (BIA), arguing that the IJ failed to inform her of her rights to apply for a waiver of removal and to seek asylum. The BIA dismissed her appeal, finding that she was not eligible for a waiver of removal and that the IJ had fulfilled his duty to inform her of her right to apply for asylum.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Seldon was not "apparently eligible" for a fraud waiver under 8 U.S.C. § 1227(a)(1)(H) because her failure to attend the interview was independent of her fraudulent actions. The court also found that the IJ did not err in failing to advise her of her right to apply for asylum, as her counsel had confirmed that she did not express fear of returning to Nigeria and would not be filing other applications for relief. Consequently, the Sixth Circuit denied Seldon's petition for review. View "Seldon v. Garland" on Justia Law

Eric Vaughn was pulled over for speeding, fled from the police, and discarded a pistol during the chase. As a convicted felon, he was indicted for unlawful possession of a firearm and pleaded guilty. The district court sentenced him to 53 months in prison and three years of supervised release, including several special conditions.At sentencing, Vaughn objected to the first special condition, which allowed the probation officer to determine the frequency of drug tests and whether he needed alcohol treatment. He requested a more specific schedule, but the district court overruled his objection, stating it would consider guidance if Vaughn felt over-tested. Vaughn did not object to the second special condition, which allowed the probation officer to decide if his mental health treatment should be inpatient or outpatient.The United States Court of Appeals for the Sixth Circuit reviewed Vaughn's appeal. Vaughn argued that the district court improperly delegated its judicial authority to the probation office by not specifying the details of his supervised release conditions. The court reviewed the first special condition de novo and the second for plain error due to Vaughn's failure to object at sentencing.The Sixth Circuit held that the district court did not improperly delegate its authority. It found that the court's use of "shall participate" language in the special conditions was sufficient to meet statutory and constitutional requirements. The court also noted that probation officers are allowed to determine the specifics of treatment programs. The court affirmed the district court's judgment, concluding that there was no improper delegation of judicial authority in Vaughn's supervised release conditions. View "United States v. Vaughn" on Justia Law

In May 2023, Martavious Kincaide pleaded guilty to three federal firearms offenses in the Western District of Kentucky. Deandre Swain, a criminal defendant in Kentucky state court, sought to intervene in Kincaide’s case to unseal a document titled “Plea Agreement Supplement.” Swain believed this document might contain a cooperation agreement that could aid his defense in his state court case. The Western District of Kentucky requires that all plea supplements, which may contain cooperation agreements, be sealed to protect cooperators from potential harm.The United States District Court for the Western District of Kentucky denied Swain’s motion to intervene. The court held that the General Order 2010-06, which mandates the sealing of plea supplements, was consistent with the First Amendment. The court reasoned that the order was the narrowest method to protect the safety of cooperators and that Swain’s specific interest did not override the need for consistency in applying the General Order.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 there is no qualified First Amendment right of access to cooperation agreements. The court applied the “experience and logic” test from Press-Enterprise Co. v. Superior Court, concluding that there is no historical tradition of public access to such documents and that public access would not play a significant positive role in the functioning of the judicial process. The court emphasized that public access to cooperation agreements could endanger cooperators and undermine government investigations. Thus, the denial of Swain’s motion to intervene was affirmed. View "United States v. Kincaide" on Justia Law

Ali Naji entered the Dearborn police station, pointed a gun at Corporal Timothy Clive, and attempted to shoot him. The gun malfunctioned, and while Naji tried to fix it, Clive shot and killed him. Hussein Naji, representing Ali Naji's estate, sued Clive and the City of Dearborn under 42 U.S.C. § 1983 for excessive force and state tort claims. The district court granted summary judgment in favor of Clive and the City on all claims.The United States District Court for the Eastern District of Michigan found that Clive's use of deadly force was objectively reasonable under the circumstances. Naji had pointed a gun at Clive and attempted to fire, posing an immediate threat. The court also noted that Clive was behind bulletproof glass and that the incident occurred in a busy police station. The court dismissed the claims against the City of Dearborn, as there was no underlying constitutional violation to support municipal liability.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court's decision. The court held that Clive's actions were objectively reasonable and that he had probable cause to believe Naji posed an immediate threat. The court also rejected the argument that Naji's mental illness should have altered the assessment of the threat. Additionally, the court found that Clive was entitled to qualified immunity and that the City of Dearborn could not be held liable without an underlying constitutional violation.The court also addressed the state law claims, finding that Clive acted in good faith and was immune from assault and battery claims under Michigan law. The court dismissed the gross negligence claim, noting that it was essentially an excessive force claim in disguise and that Naji's representative failed to establish a legal duty for Clive to follow internal departmental policies. The court affirmed the district court's grant of summary judgment in favor of Clive and the City of Dearborn. View "Naji v. City of Dearborn, Michigan" on Justia Law

Jonathon Neuhard was convicted by a jury of producing, receiving, and possessing child pornography. The evidence included testimony from his niece, MV1, who identified herself in the images and stated that Neuhard had taken them. Law enforcement found the images on a laptop and memory card in Neuhard's trailer, with metadata linking the images to his phone. Neuhard sought to vacate his sentence under 28 U.S.C. § 2255, claiming ineffective assistance of trial and appellate counsel.The United States District Court for the Eastern District of Michigan denied Neuhard's motion but granted a certificate of appealability. Neuhard argued that his trial counsel, Richard Korn, failed to adequately investigate and present evidence of his autism and did not request an evidentiary hearing regarding a government witness's mention of polygraph tests. He also contended that his appellate counsel was ineffective for not appealing the denial of his mistrial motion.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that Korn had conducted a reasonable investigation into Neuhard's autism and made a strategic decision not to present this evidence at trial, fearing it would harm Neuhard's case. The court also determined that Neuhard did not suffer prejudice from Korn's failure to request an evidentiary hearing about the polygraph testimony, as the district court had issued a clear and immediate instruction to the jury to disregard the comment.Regarding appellate counsel, the court held that the decision not to appeal the mistrial denial was within the bounds of reasonable professional judgment. The court noted that appellate counsel had raised six other issues on appeal, and the mistrial claim was not clearly stronger than the issues presented.The Sixth Circuit affirmed the district court's denial of Neuhard's § 2255 motion. View "Neuhard v. U.S." on Justia Law

Michael Walden applied multiple times for a manufacturing job with General Electric (GE) but failed the required tests each time. He sued GE for age discrimination and his union for unfair representation in his challenges to GE's hiring decisions. The district court granted summary judgment for GE and the union, and Walden appealed.The United States District Court for the Western District of Kentucky granted summary judgment in favor of GE and the union. The court found that Walden failed to establish a prima facie case of age discrimination under the Age Discrimination in Employment Act (ADEA) because he did not meet the job qualifications, specifically failing the required tests. Additionally, the court found that the union did not breach its duty of fair representation.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that Walden did not qualify for the job as he failed the required tests, and thus could not establish a prima facie case of age discrimination. The court also held that issue preclusion barred Walden's claim against the union for unfair representation, as the National Labor Relations Board (NLRB) had already adjudicated and dismissed his unfair representation charge. The court concluded that Walden had a full and fair opportunity to litigate the issue before the NLRB, and thus, his section 301 claim under the Labor Management Relations Act (LMRA) failed as a matter of law. View "Walden v. General Electric International" on Justia Law

The case involves debtors Jason and Leah Wylie, who faced financial difficulties in 2018 due to Mr. Wylie's health issues. As they prepared to file for bankruptcy, they delayed filing their 2018 and 2019 tax returns. Their accountant prepared the 2018 returns, showing significant overpayments, which the Wylies elected to apply to their 2019 tax liabilities instead of receiving refunds. This decision was repeated for their 2019 returns, which were filed shortly after they submitted their Chapter 7 bankruptcy petition.The United States Bankruptcy Court for the Eastern District of Michigan found that the Wylies transferred their anticipated 2019 tax refunds with the intent to hinder the trustee and denied them a discharge under 11 U.S.C. § 727(a)(2)(B). However, the court dismissed other counts alleging similar intent for their 2018 tax overpayments and false statements in their bankruptcy filings. The Wylies appealed the decision on Count II to the United States District Court for the Eastern District of Michigan, which reversed the bankruptcy court’s decision, holding that the finding of intent was clearly erroneous.The United States Court of Appeals for the Sixth Circuit reviewed the case and agreed with the district court. The appellate court found that the bankruptcy court’s intent findings were inconsistent and unsupported by the evidence. Specifically, the bankruptcy court had found that the Wylies’ intent in both the 2018 and 2019 tax elections was to ensure their taxes were paid, not to hinder the trustee. The appellate court emphasized that § 727(a)(2) requires specific intent to hinder the trustee, which was not demonstrated in this case. Consequently, the Sixth Circuit affirmed the district court’s decision and remanded the case to the bankruptcy court to enter a discharge for the Wylies. View "Miller v. Wylie" on Justia Law

Adrian Galvez-Bravo, a Mexican national, entered the United States in 1994 and has lived in the Memphis area since then, except for a brief return to Mexico to marry his wife. He has three children, two of whom are U.S. citizens. In 2013, the Department of Homeland Security initiated removal proceedings against him, alleging he was a noncitizen present in the U.S. without being admitted or paroled. Galvez-Bravo conceded the charge and sought cancellation of removal under § 240A of the Immigration and Nationality Act, arguing that his removal would cause exceptional and extremely unusual hardship to his U.S. citizen children.An Immigration Judge (IJ) disagreed with Galvez-Bravo's assessment of hardship, and the Board of Immigration Appeals (BIA) upheld the IJ's decision, ordering his removal to Mexico. Galvez-Bravo then filed a motion to reopen the removal proceedings, citing new evidence, including his daughter's recent dyslexia diagnosis and the potential impact on his children's education and well-being if he were removed. The BIA denied the motion, concluding that the new evidence did not meet the hardship standard required for cancellation of removal.The United States Court of Appeals for the Sixth Circuit reviewed the BIA's decision. The court confirmed its jurisdiction to review the legal challenges presented by Galvez-Bravo, noting that his arguments focused on whether the BIA engaged in reasoned decision-making. The court found that the BIA had articulated a rational explanation for its decision, considering the new evidence but determining that the hardship did not exceed what would normally be expected upon the removal of a close family member. The court also rejected Galvez-Bravo's argument that the BIA's decision was inconsistent with its prior decisions, noting that the unpublished decisions he cited did not establish a pattern of conflicting outcomes.The Sixth Circuit held that the BIA did not abuse its discretion in denying Galvez-Bravo's motion to reopen and denied his petition for review. View "Galvez-Bravo v. Garland" on Justia Law

Tamir Abdullah, a federal prisoner convicted of crack-cocaine offenses, sought to reduce his life sentence under Section 404 of the First Step Act of 2018. This act made the Fair Sentencing Act's provisions retroactive, aiming to reduce sentencing disparities between crack and powder cocaine offenses. Abdullah argued that his conviction for conspiring to distribute between 500 grams and 1.5 kilograms of crack cocaine qualified as a "covered offense" under the First Step Act, making him eligible for a sentence reduction.The United States District Court for the Northern District of Ohio initially failed to address the merits of Abdullah's motion. Instead, it construed the motion as one for "compassionate release" due to the COVID-19 pandemic and denied it, citing the low number of COVID-19 cases in Abdullah's prison. Abdullah appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court had erred in its interpretation of Abdullah's motion. However, the appellate court affirmed the denial of the motion based on intervening case law. The court held that Abdullah was not entitled to a sentence reduction under the Fair Sentencing and First Step Acts because the changes in drug quantity thresholds did not affect his mandatory life sentence. Specifically, the Fair Sentencing Act increased the threshold for a mandatory life sentence from 50 grams to 280 grams of crack cocaine, but Abdullah's conviction involved quantities well above this new threshold.Therefore, the Sixth Circuit affirmed the district court's denial of Abdullah's motion for a sentence reduction, concluding that the district court had no discretion to reduce his sentence under the applicable laws. View "United States v. Abdullah" on Justia Law