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

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law

A man seeking treatment for mental health issues voluntarily admitted himself to a hospital in Chattanooga, Tennessee. Medical staff determined he needed emergency medication and began to physically restrain him when he refused a shot. An off-duty police officer, working as a hospital security guard and wearing his police uniform, intervened. He twisted the patient's arm behind his back, and when the patient pulled away to relieve pain, the officer punched the patient’s head into a cinderblock wall, causing head trauma. The patient remained nonviolent throughout and was smaller in stature than those restraining him.Following the incident, the Chattanooga Police Department conducted an internal investigation. Opinions within the review process were divided, but the interim chief ultimately found no policy violation. The patient filed suit in the United States District Court for the Eastern District of Tennessee, alleging excessive force under 42 U.S.C. § 1983, multiple state-law torts, and municipal liability against the City for failing to train or supervise the officer. The district court granted summary judgment for the officer on all but the assault and battery claim, finding qualified immunity on the excessive force claim, and granted summary judgment for the City on all claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that, although a reasonable juror could find the officer’s use of force excessive under the circumstances, the law was not clearly established that an officer in this situation could not use such force. Therefore, the officer was entitled to qualified immunity. The court also found that the City was not liable under Monell since the plaintiff failed to demonstrate that a final policymaker’s actions were the moving force behind his injury. The district court’s judgment was affirmed. View "Guptill v. City of Chattanooga" on Justia Law

A freight train operated by Norfolk Southern derailed in East Palestine, Ohio, in early 2023, releasing hazardous materials and causing widespread evacuations and concern over health, environmental, and economic impacts. Numerous lawsuits were filed by affected individuals and businesses, which were consolidated into a master class action. The parties reached a $600 million settlement, which included provisions for a settlement fund and attorney’s fees. The district court approved the settlement and the attorney’s fees request, designating co-lead counsel to allocate fees among the plaintiffs’ attorneys, including Morgan & Morgan, a firm representing some individual claimants.After the district court in the United States District Court for the Northern District of Ohio approved the settlement and fee awards, Morgan & Morgan, despite having received nearly $8 million in fees, objected to the process and timing of fee allocation, specifically challenging the settlement’s “quick pay” provision and the authority given to co-lead class counsel to distribute fees. Morgan & Morgan also raised concerns about transparency and the adequacy of its own fee award, arguing that the allocation process might have undervalued its contributions.On appeal, the United States Court of Appeals for the Sixth Circuit held that Morgan & Morgan lacked standing to challenge the quick pay provision, as it did not suffer a concrete, particularized injury from the timing of payment and had assented to the settlement terms. The court also affirmed the district court’s decision to delegate initial fee allocation authority to co-lead class counsel, finding no abuse of discretion and noting the court retained jurisdiction for oversight. However, the Sixth Circuit found the district court had failed to address Morgan & Morgan’s specific concerns about its fee allocation and remanded that narrow issue for further consideration. The judgment was thus affirmed in part, reversed in part, and remanded. View "In re E. Palestine Train Derailment" on Justia Law

A 20-year-old man with autism developed a sexual relationship with a 12-year-old girl he met online. Although the girl claimed to be thirteen, she was in fact younger. Their conversations became sexual, and at the man’s request, the girl sent him nude and sexually explicit photos and videos. In one video, she, who was pubescent, is depicted inserting a marker into her vagina at his suggestion. Law enforcement intervened after the girl reported him, leading to his arrest when he arrived at a hotel believing he would meet her for sex.A grand jury indicted the defendant on several sex-related offenses. He pleaded guilty to receiving child pornography, enticing a minor, and attempting to transfer obscene material to a minor. The United States District Court for the Western District of Kentucky, in calculating the sentencing range under the Sentencing Guidelines, applied a four-level enhancement for material depicting “sadistic or masochistic conduct,” based on the video of the girl’s self-penetration. The court relied on prior Sixth Circuit precedent, particularly United States v. Preston, to apply this enhancement, treating penetration with a foreign object as per se sadistic. The court sentenced the defendant to 226 months’ imprisonment after some downward variance for his immaturity and autism.The United States Court of Appeals for the Sixth Circuit reviewed the sentence. The Sixth Circuit held that the district court erred by applying a categorical rule that all foreign-object penetration by a pubescent minor is per se sadistic. The appellate court clarified that for pubescent minors, the sadism enhancement requires an objective finding, based on the content of the material, of visible physical pain, emotional suffering, or humiliation—not simply penetration. The court vacated the sentence and remanded for resentencing under the correct legal standard. View "United States v. Vowels-Harper" on Justia Law

An employee at a nuclear power plant operated by a subsidiary corporation left active work due to a medical condition but remained employed while on short-term disability. After the employee transitioned to long-term disability, the employer terminated his employment. The union, representing the plant’s workers, filed a grievance on the employee’s behalf, arguing that the collective bargaining agreement (CBA) required continued employment and benefits. The union initiated arbitration against the employer but mistakenly named the employer’s parent company as the respondent. Despite the error, counsel for the correct employer participated in the arbitration, and all parties consistently identified the subsidiary as the actual employer during the proceedings.After the arbitrator issued an award in favor of the union—ordering reinstatement and benefits for the employee—the employer did not comply. Instead, the parent and subsidiary together filed suit in the United States District Court for the Western District of Michigan, seeking to vacate the award due to the mistaken caption. The union counterclaimed for confirmation of the award. The district court ruled for the union, finding extensive evidence that the subsidiary had engaged in and intended to be bound by the arbitration, and that the erroneous caption was merely a procedural defect to which the employer had waived any objection by participating fully and not raising a timely challenge.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that when an arbitration demand and award misname the party against whom the award is meant to be entered, but there is no ambiguity about the real party, a federal court may enforce the award. The court further held that any objection to the misnomer was waived by the employer’s participation and failure to object, and that the error was a curable misnomer not warranting vacatur or modification of the award. View "Holtec International Corp. v. Michigan State Utility Workers Council" on Justia Law

Two healthcare professionals operated a clinic specializing in pain management in Kentucky. One owned and managed the clinic, while the other served as its medical director. Together, they implemented a scheme to maximize profits by routinely ordering and billing insurers for both basic and more expensive, specialized urine drug tests for patients, regardless of actual medical need. The clinic eventually acquired in-house testing equipment to further increase billing. Staff raised concerns about the medical necessity of the tests and the reliability of the equipment, but the practice continued. The clinic also billed for tests conducted on malfunctioning equipment and for tests whose results could not be used for patient care due to processing delays.A grand jury indicted both individuals for conspiracy to commit health care fraud, substantive health care fraud, and (for one defendant) unlawful distribution of controlled substances. Both defendants went to trial in the United States District Court for the Eastern District of Kentucky. The jury convicted one defendant of health care fraud, and the other of both health care fraud and conspiracy to commit health care fraud. After denying post-trial motions for acquittal and new trial, the district court sentenced both to below-Guidelines imprisonment terms, after calculating loss amounts based on insurer payments for unnecessary testing, with a discount for tests likely to have been medically necessary.The United States Court of Appeals for the Sixth Circuit reviewed the convictions and sentences. The court held there was sufficient evidence to support both defendants’ convictions, upheld the district court’s evidentiary rulings (including admission of propensity and patient death evidence with limiting instructions), found no variance between the indictment and proof at trial, and determined that one defendant’s conflict-of-interest waiver was valid. The court also affirmed the district court’s methodology for estimating loss amounts for sentencing and restitution. The Sixth Circuit affirmed all convictions and sentences. View "United States v. Siefert" on Justia Law

An attorney who chaired the Davidson County Election Commission was also employed at a law firm that represented the Metropolitan Government of Nashville and Davidson County. The Election Commission became involved in a dispute over whether a citizen-initiated tax-repeal referendum should be placed on the ballot, a measure opposed by the city government and certain city council members. The attorney, acting as commission chair, supported certifying the referendum. Following pressure from city officials, including a council member who threatened to withdraw city business from the law firm if the attorney continued supporting the referendum, the law firm terminated the attorney’s employment after he refused to change his position.The attorney filed suit in the United States District Court for the Middle District of Tennessee, asserting violations of his First Amendment rights under 42 U.S.C. § 1983, among other claims. The district court denied motions to dismiss based on qualified immunity filed by both the council member and the law firm. The court concluded that the council member’s alleged conduct violated clearly established First Amendment law and that the law firm, as a private entity, was not entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit determined that both the council member and the law firm were eligible to assert qualified immunity due to their public functions in this context. The court held that the council member was not entitled to qualified immunity because the complaint plausibly alleged he violated clearly established First Amendment rights by causing the attorney’s firing due to protected speech. However, the court found that the law firm was entitled to qualified immunity, as there was no clearly established law prohibiting a law firm from firing an employee in response to client pressure under these circumstances. Accordingly, the Sixth Circuit affirmed the denial of qualified immunity for the council member, reversed as to the law firm, and remanded for further proceedings. View "DeLanis v. Metropolitan Government of Nashville" on Justia Law

A corrections officer employed by the Michigan Department of Corrections suffered a significant hip injury while performing his duties, which led to extended medical leave and ultimately permanent work restrictions. After exhausting his leave, he was placed in a transitional employment position within the department, but this assignment was temporary and not designed to be indefinite. The employee requested a permanent accommodation due to his ongoing disability, but the department denied the request, citing a lack of suitable vacancies. He then entered a leave status that preserved certain employment benefits but ended his active employment. During this period, he became the subject of workplace misconduct investigations, though the most serious allegations were not substantiated. After recovering from surgery, he sought reinstatement but was denied due to an unresolved disciplinary matter, and later declined offers to return to work.He brought suit in the United States District Court for the Eastern District of Michigan, alleging claims under § 504 of the Rehabilitation Act for failure to accommodate his disability and for retaliation in response to his accommodation request and related legal actions. The district court granted summary judgment to the defendants on the failure-to-accommodate claim, finding he was not qualified for his original position with or without reasonable accommodation. The retaliation claim was tried before a jury, which found for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit was asked to determine, among other issues, whether § 504 of the Rehabilitation Act provides a private cause of action for retaliation. The court held that it does not, concluding that neither the text of § 504 nor its cross-reference to the Americans with Disabilities Act unambiguously creates such a cause of action, as required for Spending Clause legislation. The court also affirmed the district court’s summary judgment on the failure-to-accommodate claim, finding no genuine dispute of material fact. The judgment for the defendants was affirmed. View "Smith v. Michigan Department of Corrections" on Justia Law

A Guatemalan national, who entered the United States without inspection in 1994 and lived in Michigan, was detained in 2019 following a DUI conviction and placed into removal proceedings. He sought cancellation of removal under the Immigration and Nationality Act, citing his youngest daughter, a U.S. citizen, as his qualifying child. At the time of his removal hearing before the immigration judge (IJ) in April 2020, his daughter was seventeen years old.The IJ granted his application for cancellation of removal, finding him credible and of good moral character, and determining that his daughter would suffer exceptional and extremely unusual hardship if he were removed. The Department of Homeland Security appealed to the Board of Immigration Appeals (BIA), but did not challenge whether his daughter qualified as a "child"—their appeal focused on whether the hardship standard was met. The BIA did not address the merits of the IJ’s findings. Instead, in February 2025, the BIA vacated the IJ’s decision and ordered removal, reasoning that the daughter was over twenty-one when the BIA ruled and therefore no longer a qualifying child under the statute.On review, the United States Court of Appeals for the Sixth Circuit considered when a noncitizen’s child’s age should be assessed for cancellation of removal eligibility under 8 U.S.C. § 1229b(b)(1)(D). The court held that the relevant time to determine whether the individual has a qualifying child is when the IJ issues its decision, not when the BIA acts on appeal. Accordingly, the Sixth Circuit granted the petition for review and reversed the BIA’s decision, reinstating the IJ’s grant of cancellation of removal. View "Filadelfo Perez-Perez v. Bondi" on Justia Law

In this case, the petitioner was convicted by a Michigan state jury of first-degree murder, being a felon in possession of a firearm, and felony firearm. The homicide occurred in a Detroit neighborhood known for drug trafficking, where the victim was found with multiple gunshot wounds and no physical evidence tying any individual to the crime. Two witnesses, both local drug dealers, initially denied knowledge of the shooting but later identified the petitioner as the shooter after being arrested on unrelated charges. Their trial testimony was the primary evidence against the petitioner, as there was no physical evidence or eyewitness identification from the scene.Following his conviction, the petitioner pursued direct appeals and post-conviction relief through the Michigan courts, asserting ineffective assistance of counsel. Those efforts were unsuccessful. He then filed a federal habeas petition, which was denied. Years later, he sought state court relief again, now relying on an affidavit from another individual who claimed to have witnessed the murder and identified a different perpetrator. The state trial court rejected this new evidence as unreliable and insufficient to overcome procedural barriers, and subsequent appeals in the state courts were denied. The petitioner returned to federal court with a second habeas petition, presenting affidavits including recantations and new claims of innocence. The U.S. District Court for the Eastern District of Michigan dismissed the petition, finding it untimely and failing to meet the stringent requirements for successive habeas petitions.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. It agreed that the petitioner did not satisfy the gatekeeping requirements for successive petitions under 28 U.S.C. § 2244(b)(2)(B), nor did he establish grounds for equitable tolling based on actual innocence. The Sixth Circuit held that the new affidavits presented were unreliable and would not clearly and convincingly prevent any reasonable juror from convicting the petitioner. The court affirmed the district court’s dismissal of the habeas petition. View "Houston v. Tanner" on Justia Law