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

An individual who founded a Michigan biomedical research company sold a majority stake in 2019 to four defendants but retained a minority interest, later becoming dissatisfied with the company’s management and moving out of state. The new owners aimed to expand the company but withheld information from the plaintiff about their efforts to secure financing, including discussions with Avista Capital Partners, a venture capital firm that ultimately made a large investment. The plaintiff sold his shares in December 2020 for a price based on an annual valuation, prior to Avista’s capital infusion that significantly increased the company’s value. The plaintiff later sued, alleging violations of federal and state securities laws, breach of fiduciary duty under Michigan law, and various fraud and contract claims based on the defendants’ failure to disclose material facts about the company’s pursuit of equity financing and Avista’s interest.The case was first heard in the United States District Court for the Western District of Michigan. That court denied the defendants’ motion to dismiss but, following discovery, granted summary judgment in favor of the defendants on all counts. The court concluded that the omissions were not material under federal securities law and, applying Delaware law and a federal standard, also found no materiality for the breach of fiduciary duty claim under Michigan law.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment as to the federal securities law claims, the Michigan Uniform Securities Act claim, and the contract-based claims, holding that the omissions were not material under the applicable federal standards. However, the Sixth Circuit reversed the summary judgment for the Michigan common-law fiduciary duty and fraud claims, finding the district court had applied an incorrect legal standard and that genuine disputes of material fact remained. The case was remanded for further proceedings on the fiduciary duty and fraud counts. View "Boyd v. Northern Biomedical Research Inc." on Justia Law

Dustin Booth, who had a history of stable employment and no prior mental health issues, began exhibiting signs of severe mental illness in early 2022 after changes in his substance use. His erratic behavior escalated over several days, culminating in a violent incident at home and a lengthy standoff with police after he barricaded himself inside his house. Booth’s wife repeatedly sought police intervention, expressing concerns that he was a danger to himself and others, and noted his access to firearms. After attempts to calm Booth and persuade him to leave his house, he eventually left with a friend, taking a gun with him. Police stopped the vehicle, leading to a confrontation in which Booth brandished the firearm and was fatally shot by officers.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants on all federal claims. The district court held that the proposed accommodation under the Americans with Disabilities Act (ADA)—that officers should have used de-escalation techniques—was unreasonable due to the safety risks posed by Booth. The court further found that the officers’ actions during the traffic stop and subsequent use of force, including the deployment of a police dog and takedown maneuver, were reasonable under the Fourth Amendment. It also declined to exercise supplemental jurisdiction over the state-law claims.Upon review by the United States Court of Appeals for the Sixth Circuit, the appellate court affirmed the district court’s decision. The Sixth Circuit held that, as a matter of law, the ADA did not require officers to accommodate Booth’s disability in the face of objective safety risks. Additionally, the court found the officers had probable cause for a mental-health seizure and acted reasonably under the Fourth Amendment in both the stop and use of force. The judgment in favor of the defendants was affirmed. View "Booth v. Lazzara" on Justia Law

A Kentucky high school intended to administer a mental-health survey to its students. Concerned about the survey’s contents, a parent requested a copy under the Kentucky Open Records Act, aiming to share it with other parents and reporters. The school denied her request, citing a provision of the state law that excludes records “prohibited by federal law or regulation” from disclosure, and argued that the survey was copyrighted by its publisher, NCS Pearson. The school did allow her to inspect the survey in person, but would not provide a copy.The parent, Miranda Stovall, did not pursue available state remedies, such as review by the Kentucky Attorney General or a state court appeal. Instead, she filed suit in the United States District Court for the Western District of Kentucky, seeking a declaratory judgment that releasing the survey would fall under the fair-use exception in federal copyright law. NCS Pearson moved to dismiss for lack of jurisdiction, and the district court dismissed the case, finding that Stovall’s claim did not arise under federal law.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. The appellate court held that federal jurisdiction was lacking because Stovall’s claim arose under state law, not the Copyright Act, and did not “necessarily raise” a substantial federal question. The court found that copyright law entered the dispute only as a defense to the state-law claim, and that potential future infringement actions did not establish Article III standing. The court affirmed the district court’s dismissal for lack of federal subject-matter jurisdiction. View "Stovall v. Jefferson Cnty. Bd. of Education" on Justia Law

Plaintiff Stacy Cales, a nurse practitioner, owned Road to Recovery, LLC, a substance abuse treatment business in West Virginia. In 2020, Cales engaged attorney Kristopher Justice, from the Ohio firm Theisen Brock, LPA, to assist in selling her business. Justice drafted sales documents, including a Promissory Note that defined payment terms and specified a liquidated damages amount in the event of default. Cales expressed concern to Justice about the damages provision, fearing it would limit her recovery if the buyer defaulted. Justice reassured her that the contract’s implied covenant of good faith would prevent the buyer from exploiting the provision. After the buyer ceased payments, litigation ensued in West Virginia, where the buyer asserted that damages should be limited to the liquidated amount. Dissatisfied with her representation and the contract, Cales hired a new attorney, who later advised her that she was entitled only to liquidated damages, prompting her to settle.Plaintiffs subsequently filed a legal malpractice claim and a vicarious liability claim in the United States District Court for the Southern District of Ohio. Both sides moved for summary judgment. The district court granted summary judgment for defendants, holding that the Ohio one-year statute of limitations barred plaintiffs' claims. The court reasoned that the statute began running when Cales terminated her prior attorney in March 2022, as that constituted a “cognizable event.”On appeal, the United States Court of Appeals for the Sixth Circuit held that the statute of limitations began on April 13, 2023, when Cales was advised by her new attorney about the consequence of the liquidated damages provision. Since the complaint was filed within one year of that date, the claims were timely. The appellate court reversed the district court’s judgment and remanded for further proceedings. View "Cales v. Theisen Brock LPA" on Justia Law

MTG, Inc., a company specializing in tooling for the auto industry, filed for Chapter 11 bankruptcy in 1995, which was later converted to a Chapter 7 proceeding in 1996. Charles Taunt was appointed as the Chapter 7 trustee and, during his tenure, entered into a fee agreement with Comerica Bank, MTG's largest secured creditor. Taunt failed to disclose this agreement to the bankruptcy court, despite rules requiring disclosure of such connections. Several orders were issued during this time that benefited Comerica, including allowance of its claim, relief from stay, and settlement of pre-petition lender liability claims. After Taunt's undisclosed conflict of interest was revealed, litigation ensued over whether the resulting orders should be set aside and whether Taunt, his law firms, and Comerica were liable for fraud, conversion, and unauthorized transfers.Following discovery of Taunt's conflict, the United States Bankruptcy Court for the Eastern District of Michigan vacated the orders benefitting Comerica and found Taunt and his law firm had committed fraud on the court. Taunt was disqualified as trustee, his firm was denied fees, and Guy Vining was appointed as successor trustee. Vining initiated an adversary proceeding with multiple claims, primarily post-petition claims alleging fraud on the court, avoidable transfers, and conversion. The bankruptcy court granted summary judgment for defendants on most claims, awarding only limited attorney’s fees for exposing the fraud. The United States District Court for the Eastern District of Michigan affirmed these rulings.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held Comerica was not directly or vicariously liable for fraud on the court, as it was not an officer of the court and did not control Taunt. The court also ruled that the challenged post-petition transfers were authorized by valid court orders and thus not avoidable under bankruptcy law. Finally, the court found Taunt’s actions as trustee were authorized, rejecting the conversion claim. The limited attorney’s fees award and denial of punitive damages were upheld as within the bankruptcy court’s discretion. View "Vining v. Plunkett Cooney, P.C." on Justia Law

While released on bond for a burglary charge, the defendant evaded police during a traffic stop, abandoning his truck in a pond and fleeing on foot. The next day, officers returned and, after a series of encounters involving the defendant and his girlfriend, discovered multiple firearms and ammunition in a nearby SUV, to which the defendant later admitted ownership. Because he had a prior felony conviction, a grand jury indicted him for being a felon in possession of a firearm under federal law. The defendant entered into a plea agreement with the government, recommending certain offense levels and sentencing enhancements, but the agreement did not bind the district court.The United States District Court for the Eastern District of Kentucky received a presentence report that calculated a higher base offense level than the plea agreement had contemplated, after discovering an additional prior controlled substance conviction. Both parties acknowledged the report’s accuracy at sentencing, though they advocated for a lower sentence in line with the plea agreement. The government also acknowledged the court’s independent authority to calculate the guidelines. Ultimately, the district court adopted the presentence report’s range and sentenced the defendant to 110 months, at the bottom of the applicable guidelines range.The United States Court of Appeals for the Sixth Circuit reviewed whether the government breached the plea agreement and whether the sentence was unreasonable. The court held that the government had not breached the plea agreement because the agreement allowed either party to argue for other guideline calculations, and the government did not recommend a higher sentence. The court also found that the sentence was both procedurally and substantively reasonable, as the district court considered the relevant statutory factors and the defendant’s history. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Messersmith" on Justia Law

In 1989, a man committed a brutal murder at a Kentucky laundromat, killing a 61-year-old employee after she asked him to leave. After his arrest, he was charged with several crimes, including murder. Five years later, he pleaded guilty to all charges. He sought to have a judge, rather than a jury, decide his sentence, hoping for a more favorable outcome due to the nature of his crimes. After a series of legal maneuvers and a failed attempt to withdraw his guilty plea, a judge ultimately sentenced him to death, despite the presentation of significant mitigating evidence about his abusive childhood and mental health struggles.On direct appeal, the Kentucky Supreme Court affirmed both his conviction and sentence, rejecting his arguments that his guilty plea was not knowing and voluntary and that the sentencing court had failed to consider all mitigating evidence. The court found that while the trial court’s plea colloquy did not specifically enumerate every right waived by pleading guilty, it was sufficient to show that the defendant understood the consequences. The court also concluded that the sentencing judge had considered all mitigating evidence, even if he found it unpersuasive.After exhausting state postconviction remedies, the petitioner filed a federal habeas corpus petition in the United States District Court for the Eastern District of Kentucky, raising multiple grounds for relief. The district court denied relief and declined to issue a certificate of appealability. The United States Court of Appeals for the Sixth Circuit granted a limited certificate and reviewed two claims de novo: whether the plea was knowing and voluntary, and whether the trial court failed to consider mitigating evidence.The Sixth Circuit held that the Kentucky Supreme Court had not unreasonably applied clearly established federal law in either respect. The record affirmatively demonstrated the petitioner’s understanding of his rights, and the sentencing court’s consideration of mitigation evidence was constitutionally adequate. Accordingly, the Sixth Circuit affirmed the district court’s denial of habeas relief. View "Johnson v. Plappert" on Justia Law

Two fourteen-year-old girls residing in a group home in Dayton, Ohio, contacted Kelly Richards, a man they knew as “Scorpio,” and asked him to pick them up. Richards transported the girls to his apartment in Cincinnati, where he facilitated their drug use, sexually assaulted them, and coerced them into prostitution over several days. He controlled their movements, threatened them with weapons, and advertised them online for sex. The girls eventually escaped, and authorities began an investigation that uncovered substantial evidence connecting Richards to their exploitation, including digital communications and photographs.The United States District Court for the Southern District of Ohio reviewed the evidence and denied Richards’s suppression motion, finding probable cause supported the search warrants. Richards proceeded to a jury trial, which resulted in convictions on two counts of sex trafficking minors, two counts of sexually exploiting children, and one count of possessing a firearm as a felon. He was sentenced to 480 months in prison and a life term of supervised release. Richards raised several legal challenges before and during trial, including claims regarding the Speedy Trial Act, search warrant validity, denial of self-representation, limits on cross-examination, and the substantive reasonableness of his sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The Sixth Circuit held that Richards’s trial occurred within the statutory and constitutional limits for a speedy trial, the search warrants were supported by probable cause and did not require a Franks hearing, the district court did not abuse its discretion in denying mid-trial self-representation, and limiting cross-examination of the government’s agent did not violate Richards’s rights. The court also found Richards’s below-Guidelines sentence substantively reasonable and denied his motion to file a supplemental pro se brief. The judgment and sentence were affirmed. View "United States v. Richards" on Justia Law

A former elected county prosecutor in Kentucky’s 21st Judicial Circuit was charged with Honest Services Wire Fraud, violations of the Travel Act, and Federal Program Bribery. The charges stemmed from an arrangement with a young woman, M.H., who repeatedly faced legal troubles. Evidence showed that the prosecutor agreed to help her with matters such as getting warrants withdrawn, charges reduced, and release from jail, in exchange for sexual acts and explicit images. The FBI discovered the scheme, leading to federal prosecution. At trial, the government presented incriminating text messages, testimony from M.H., and law enforcement, while the defendant claimed he did not solicit images and that M.H. was assisting in investigations—a claim disproved by evidence.The United States District Court for the Eastern District of Kentucky oversaw the jury trial, which resulted in convictions on all counts. The court sentenced the defendant to 41 months in prison and imposed supervised release conditions, including refraining from excessive alcohol use. On appeal to the United States Court of Appeals for the Sixth Circuit, the defendant challenged the exclusion of certain testimony about Kentucky law, sufficiency of the evidence on several elements, the federal funding nexus for the bribery charge, the supervised release condition, and the sentencing court’s refusal to consider “collateral consequences.”The Sixth Circuit held that the district court did not abuse its discretion or violate constitutional rights in excluding expert legal opinion testimony and that the jury was properly instructed on the meaning of “official acts.” The court found overwhelming evidence supporting the verdict, including proof of a quid pro quo and an interstate nexus. The federal funding requirement was satisfied by evidence that the state received sufficient funds. The supervised release condition and sentencing decisions were not plainly erroneous. The Sixth Circuit affirmed the district court’s judgment in all respects. View "United States v. Goldy" on Justia Law

In this case, federal prosecutors charged several members of the Junk Yard Dogs, a Memphis-area gang affiliated with the Almighty Vice Lord Nation, with racketeering, murder, attempted murder, and firearms offenses stemming from a violent gang war in the summer of 2020. The indictment followed a spree of shootings that injured multiple people and left one dead. Of the fifteen indicted, most pled guilty, but Tomarcus Baskerville (gang leader), Thomas Smith (second-in-command), and Courtland Springfield (foot soldier) went to trial. Extensive evidence at trial included testimony from cooperating codefendants, phone records, and physical evidence linking the defendants to coordinated attacks against rival gangs.The United States District Court for the Western District of Tennessee presided over the trial. After lengthy deliberations, the jury convicted Baskerville, Smith, and Springfield on various racketeering and violent crime counts. There were challenges during deliberations related to suspected jury intimidation, but after polling jurors and interviewing the foreperson, the district court found the jury remained impartial and denied motions for mistrial. Springfield was acquitted of certain charges, and another defendant was acquitted entirely.The United States Court of Appeals for the Sixth Circuit reviewed the convictions and sentences. The court affirmed all convictions, finding the evidence sufficient and rejecting arguments for mistrial or the necessity of individual juror questioning. The court held that the district court did not abuse its discretion in handling jury intimidation claims and properly admitted the government’s phone chart exhibits. However, consistent with the government’s concession, the Sixth Circuit vacated Smith’s sentence related to his firearm conviction and remanded for resentencing, ruling that the mandatory minimum sentence imposed exceeded what the jury’s findings supported under federal law. View "United States v. Baskerville" on Justia Law