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

A resident of University Heights, Ohio, who practices Orthodox Judaism, sought to use his home for group prayer sessions due to religious obligations and restrictions on travel during the Sabbath. After inviting neighbors to participate in these gatherings, a neighbor complained to city officials, prompting the city’s law director to send a cease-and-desist letter, warning that using the home as a place of religious assembly violated local zoning laws. The resident then applied for a special use permit to operate a house of worship but withdrew his application before the city’s Planning Commission could reach a decision, stating he did not wish to operate a house of worship as defined by the ordinance. Despite withdrawing, he later filed a federal lawsuit against the city and several officials, alleging violations of federal and state law, including constitutional and statutory claims.The United States District Court for the Northern District of Ohio granted summary judgment for the city and its officials. The court found that the plaintiff’s claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the First and Fourteenth Amendments, and the Ohio Constitution were unripe because there was no final decision by the relevant local authorities regarding the application of the zoning ordinance to his property. The court also rejected his Fourth Amendment and Freedom of Access to Clinic Entrances Act (FACE Act) claims on the merits and declined supplemental jurisdiction over a state public records claim.The United States Court of Appeals for the Sixth Circuit affirmed. The court held that most of the plaintiff’s claims were unripe because he withdrew his application before any final decision was made by the city’s zoning authorities, and thus there was no concrete dispute for federal review. The court also held that his facial challenges to the ordinance were forfeited and, in any event, failed as a matter of law. The court further concluded that the Fourth Amendment and FACE Act claims failed on the merits and found no abuse of discretion in declining supplemental jurisdiction over the state law claim. View "Daniel Grand v. City of University Heights, Ohio" on Justia Law

A former employee of a county health department brought suit under the Americans with Disabilities Act (ADA), alleging that her employer discriminated against her based on her night blindness, retaliated against her for requesting an accommodation, and failed to accommodate her asthma. She had been promoted to a position requiring some nighttime driving, which became increasingly difficult due to her night blindness. Later, she was reassigned to a shift that required her to work alone at night at a location she considered unsafe, and she raised concerns about both her vision and personal safety. She also experienced a severe asthma flare-up when she temporarily lost access to her medication, which affected her ability to work.The United States District Court for the Western District of Tennessee dismissed her constitutional claims but allowed her ADA claims to proceed to trial. At trial, the jury found in her favor on all three ADA claims: failure to accommodate her asthma, discrimination based on her night blindness, and retaliation for requesting an accommodation. The county moved for judgment as a matter of law at several points, arguing that her conditions did not qualify as disabilities under the ADA and that the evidence was insufficient, but the district court denied these motions.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of judgment as a matter of law de novo, considering the evidence in the light most favorable to the plaintiff. The appellate court held that the jury reasonably found that both night blindness and asthma could qualify as disabilities under the ADA, given the broad and individualized inquiry required by the statute and its amendments. The court also found sufficient evidence to support the jury’s findings of discrimination, retaliation, and failure to accommodate. Accordingly, the Sixth Circuit affirmed the district court’s judgment in favor of the plaintiff on all ADA claims. View "Edwards v. Shelby Cnty., Tenn." on Justia Law

Donovan Lewis, a twenty-year-old Black man, was fatally shot by a Columbus police officer while in bed at his apartment during an attempted arrest on outstanding warrants. His estate filed a civil rights lawsuit under 42 U.S.C. § 1983 against the City of Columbus and the police chief, alleging that the city’s police department maintained a policy or custom of racially discriminatory policing and excessive force, which led to Lewis’s death. The complaint sought damages and permanent injunctive relief, including specific reforms to police disciplinary and employment practices that were rooted in the collective bargaining agreement (CBA) negotiated by the Fraternal Order of Police (FOP), Capitol City Lodge #9.After the estate initiated the suit, FOP moved to intervene as of right or, alternatively, permissively, arguing that the proposed reforms would violate the CBA and impact its legal obligations as the exclusive bargaining representative for Columbus police officers. The United States District Court for the Southern District of Ohio denied FOP’s motion without prejudice, finding that FOP had only a limited interest in the remedial phase and that any liability-phase interest was adequately represented by the City. The court invited FOP to renew its motion if the estate prevailed or if settlement discussions occurred.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of intervention. The Sixth Circuit held that FOP satisfied all requirements for intervention as of right under Federal Rule of Civil Procedure 24(a)(2): FOP demonstrated a substantial legal interest in the subject matter, impairment of its interests absent intervention, and that the City may not adequately represent those interests. The court concluded that FOP should be allowed to intervene in all phases of the litigation and reversed the district court’s denial of intervention. View "Estate of Lewis v. City of Columbus, Ohio" on Justia Law

California Palms Addiction Recovery Campus, Inc., an Ohio rehabilitation center, and its owner, Sebastian Rucci, became the subjects of a federal criminal investigation in 2021. Pursuant to ex parte warrants issued by a magistrate judge, the FBI seized $603,902.89 from their accounts. Shortly thereafter, state agencies revoked the facility’s provider certification and terminated its Medicaid agreement. The plaintiffs filed a civil action in the United States District Court for the Northern District of Ohio, seeking the return of the seized funds and disclosure of the affidavits used to obtain the warrants, alleging constitutional defects and asserting a right to inspect the affidavits under the Fourth Amendment.The Government moved to stay the civil action, indicating its intent to pursue a civil forfeiture proceeding regarding the seized funds. After initiating the forfeiture case, the Government moved to dismiss the plaintiffs’ civil action, arguing that the statutory forfeiture process provided the appropriate remedy. The district court stayed the civil action pending resolution of the forfeiture case. In September 2024, the Government voluntarily dismissed the forfeiture proceeding and returned the funds with interest to the plaintiffs. The district court then ordered the plaintiffs to show cause why the civil action should not be dismissed as moot. Despite the plaintiffs’ argument that their claim for disclosure of the warrant affidavits remained unresolved, the district court dismissed the entire action as moot, reasoning that the plaintiffs had received the relief sought.On appeal, the United States Court of Appeals for the Sixth Circuit held that, while the claim for return of funds was moot, the claim for disclosure of the warrant affidavits was not. The court vacated the district court’s dismissal of the affidavit disclosure claim and remanded for further proceedings, holding that the existence of a live controversy over the disclosure request precluded dismissal for mootness. View "California Palms v. United States" on Justia Law

A shift supervisor at a coffee shop in Ann Arbor, Michigan, led efforts to organize a union at her workplace. She was a prominent organizer, engaging in various activities such as wearing union buttons, speaking to customers about unionization, and attending a labor board hearing. Several months into the campaign, she was terminated by her employer, who cited her violation of a company policy requiring at least two employees to be present in the café. The supervisor had left a barista alone at the store at the end of her shift without notifying management, which the company claimed was the reason for her discharge.After her termination, Workers United filed unfair labor practice charges with the National Labor Relations Board (NLRB), alleging that the discharge was motivated by anti-union animus. An Administrative Law Judge found in favor of the union, concluding that the employer’s stated reason was pretextual and that the discharge was unlawfully motivated. The NLRB affirmed the ALJ’s decision and expanded the remedy, ordering the employer to compensate the supervisor not only for lost earnings and benefits but also for any “direct or foreseeable pecuniary harms” resulting from the discrimination.The United States Court of Appeals for the Sixth Circuit reviewed the case on the NLRB’s application for enforcement of its order. The court held that substantial evidence supported the NLRB’s finding that the supervisor’s discharge was motivated by anti-union animus and thus constituted an unfair labor practice. However, the court determined that the NLRB exceeded its statutory authority under the National Labor Relations Act by awarding compensation for “direct or foreseeable pecuniary harms” beyond lost earnings and benefits. The court granted enforcement of the unfair labor practice finding but vacated the expanded remedy and remanded for further proceedings. View "National Labor Relations Board v. Starbucks Corp." on Justia Law

A train operated by Norfolk Southern carrying hazardous materials derailed near East Palestine, Ohio, in February 2023. The cleanup released toxic chemicals into the surrounding area, prompting affected residents and businesses to file suit against the railroad and other parties in federal court. These cases were consolidated into a master class action, and after extensive discovery and mediation, Norfolk Southern agreed to a $600 million settlement for the class. The district court for the Northern District of Ohio approved the settlement in September 2024. Five class members objected and appealed, but the district court required them to post an $850,000 appeal bond by January 30, 2025, to cover administrative and taxable costs. The objectors did not pay the bond or offer a lesser amount.After the bond order, the objectors filed a motion in the United States Court of Appeals for the Sixth Circuit to eliminate or reduce the bond, but did not seek a stay. The Sixth Circuit motions panel explained that, absent a separate notice of appeal, it could only address the bond on a motion to stay, which the objectors expressly disclaimed. The objectors then moved in the district court to extend the time to appeal the bond order, but did so one day after the deadline set by Federal Rule of Appellate Procedure 4(a)(5)(A). The district court denied the motion as untimely, finding it lacked jurisdiction to grant an extension.The United States Court of Appeals for the Sixth Circuit held that the deadlines for appealing and requesting extensions are jurisdictional and cannot be equitably extended. The court dismissed the objectors’ appeal of the motion to extend for lack of jurisdiction and granted the plaintiffs’ motion to dismiss the objectors’ appeals of the settlement for failure to pay the required bond. View "In re E. Palestine Train Derailment" on Justia Law

After pleading guilty to federal drug-distribution conspiracy charges in 2012, the defendant was sentenced to ten years in prison followed by eight years of supervised release. He began his supervised release in 2019. In 2022, while still under supervision, he shot and killed a man outside a convenience store, an act captured on security video. He subsequently pled guilty to murder in state court. This new criminal conduct constituted a violation of the conditions of his federal supervised release.Following the murder conviction, the United States District Court for the Eastern District of Michigan revoked the defendant’s supervised release. At the revocation hearing, the court considered the advisory Sentencing Guidelines, which recommended a range of 51 to 63 months, but imposed the statutory maximum of 60 months’ imprisonment. The court ordered this sentence to run consecutively to the defendant’s state sentence. The defendant objected to both the length of the federal sentence and the decision to run it consecutively, but did not object to the court’s consideration of the seriousness of the supervised-release violation.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the sentence. Applying plain-error review to the procedural challenge, the court held that the district court did not treat the seriousness of the supervised-release violation as a mandatory factor, but permissibly considered it as a breach of trust. The court also found no abuse of discretion in the substantive reasonableness of the sentence, noting that the district court considered multiple relevant factors and imposed a within-Guidelines sentence. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Patterson" on Justia Law

A police dispatcher who worked for a Michigan city alleged that she and other female dispatchers were required to conduct searches of female arrestees, even when female officers were available, exposing them to health and safety risks. The department did not have a similar policy for male dispatchers. In 2020, the dispatcher and several colleagues filed a lawsuit alleging sex discrimination. Eleven days after filing, the dispatcher became the subject of an Internal Affairs investigation, which ultimately led to her termination for violating department policy by using a case-management system for personal reasons. She later settled with the department, resulting in her reinstatement with a demotion, suspension, and loss of promotion eligibility.Following these events, the dispatcher filed a second lawsuit in the United States District Court for the Eastern District of Michigan, claiming that the city and its police commissioner retaliated against her for exercising her First Amendment rights by filing the original lawsuit. She also brought a claim under Michigan’s Elliott-Larsen Civil Rights Act. The district court granted summary judgment to the city on the retaliation claim, finding no municipal liability, but denied summary judgment to the commissioner in his individual capacity, holding that there was a genuine issue of material fact regarding causation. The commissioner appealed, asserting qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity. The court held that the dispatcher alleged legally cognizable adverse actions and that her right to be free from retaliation for protected speech was clearly established. The court affirmed the district court’s denial of qualified immunity to the commissioner and dismissed the remainder of the appeal for lack of appellate jurisdiction over factual disputes. The court declined to exercise pendent appellate jurisdiction over the state-law claims. View "DeVooght v. City of Warren" on Justia Law

A partnership purchased a historic eleven-story building in downtown Cleveland for $6 million in 2015 and later redeveloped it into residential apartments, utilizing state and federal historic preservation tax credits. In 2016, the partnership donated a conservation easement on the building’s façade and development rights to a local charity, claiming a $22 million charitable deduction—substantially more than the purchase price. The Internal Revenue Service (IRS) disallowed the deduction, citing that it was claimed in the wrong tax year, was grossly overvalued, and lacked proper documentation for related expenses. The IRS also imposed significant penalties for negligence and overvaluation.The partnership and its tax matters partner challenged the IRS’s determinations in the United States Tax Court. After a trial, the Tax Court found that the deduction was improperly claimed by the partnership for a period when it was not a taxable entity, as it had only one partner at the time of the donation. The court also concluded that the easement’s valuation was speculative and unsupported, rejecting the $22 million figure in favor of the IRS’s much lower estimate. Additionally, the Tax Court determined that the partnership failed to adequately document its claimed expenses and upheld the IRS’s penalties.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the Tax Court’s decision. The Sixth Circuit held that the partnership could not claim the deduction for a period when it was not a taxable partnership, that the valuation of the easement was grossly overstated and speculative, and that the partnership failed to substantiate its claimed expenses. The court also upheld the imposition of negligence and gross valuation misstatement penalties, finding no clear error in the Tax Court’s factual determinations. View "Corning Place Ohio, LLC v. Commissioner of Internal Revenue" on Justia Law

The defendant, a long-time drug trafficker, was convicted for conspiring to distribute oxycodone in rural Appalachian communities. His criminal history included two prior drug distribution convictions, and he was previously sentenced as a career offender, resulting in a lengthy prison term, supervised release, and a fine. After a series of unsuccessful post-trial motions and appeals, a change in Sixth Circuit law regarding the definition of a “career offender” under the Sentencing Guidelines made him eligible for resentencing. At resentencing, the defendant presented evidence of rehabilitation and mitigating personal history, and requested a sentence within the recalculated, lower Guidelines range.Previously, the United States District Court for the Eastern District of Kentucky had sentenced the defendant above the Guidelines range, citing his recidivism and lack of remorse. The United States Court of Appeals for the Sixth Circuit affirmed both the conviction and sentence. However, after the Sixth Circuit’s en banc decision in United States v. Havis, which narrowed the definition of a “controlled substance offense,” the defendant successfully moved for relief under 28 U.S.C. § 2255, leading to resentencing without the career offender enhancement. At resentencing, the district court imposed a sentence at the top of the new Guidelines range, reduced the term of supervised release, and reimposed the fine.On appeal, the United States Court of Appeals for the Sixth Circuit held that the district court did not err in denying a reduction for acceptance of responsibility, in its consideration of sentencing disparities, or in its treatment of mitigating evidence. The appellate court also found no plain error in the imposition of supervised release conditions. The sentence was affirmed, but the case was remanded to the district court for consideration of a retroactive sentencing amendment (Amendment 821). The request for reassignment to a different judge was denied. View "United States v. Coleman" on Justia Law