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

Law enforcement officers responded to a report of an open door at Chad Taylor’s townhouse in Boone County, Kentucky. Inside, they found signs of recently fired gunshots, including bullet holes and spent shell casings. After obtaining search warrants, officers found ammunition and methamphetamine in Taylor’s possession. Taylor admitted to using methamphetamine and exhibited paranoid, erratic behavior, claiming people were watching him. The following day, Taylor was found at his home with a loaded Glock 19, and ballistics matched it to the earlier gunfire. Taylor had prior felony convictions for drug trafficking, intimidation, and misdemeanor domestic battery.A grand jury indicted Taylor for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The United States District Court for the Eastern District of Kentucky initially detained Taylor but later released him on conditions due to his history of substance abuse and the risk he posed. Taylor moved to dismiss the indictment, arguing that the statute was unconstitutional both facially and as applied. The district court denied the motion, finding Taylor dangerous based on his prior convictions, and subsequently sentenced him to 30 months’ imprisonment after he pled guilty but reserved his right to appeal the constitutional issue.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the constitutionality of § 922(g)(1) as applied to Taylor in light of recent circuit precedent. The appellate court held that the dangerousness assessment required for firearm disqualification is distinct from the assessment for pretrial detention. Applying the standard set forth in United States v. Williams, the court found that Taylor’s offense conduct and criminal history—including felony drug trafficking, intimidation, and domestic battery—demonstrated that he was dangerous. The court affirmed the district court’s judgment, holding that § 922(g)(1) is constitutional as applied to Taylor. View "United States v. Taylor" on Justia Law

An eighteen-year-old individual pleaded guilty in a Michigan court to a felony charge for carrying a concealed weapon. Rather than entering a judgment of conviction, the court placed him in a diversion program for youthful offenders under the Holmes Youthful Trainee Act, which deferred both conviction and judgment. The program allowed the court to enter a conviction at any time if the individual failed to meet its requirements. While still participating in this program and on probation, the individual was arrested and admitted possession of a firearm with an obliterated serial number, leading to federal charges.The United States District Court for the Western District of Michigan presided over the federal case. At sentencing, the court adopted the presentence report’s finding that the defendant’s offense level should be increased because he was a “prohibited person” under federal law at the time of the firearm offense, due to his pending felony charge in Michigan. The court concluded that the deferred status under the Michigan program meant the original felony information remained pending, qualifying him as being “under indictment” for purposes of federal firearms restrictions. The district court sentenced him to 48 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit considered whether participation in Michigan’s diversion program constituted being “under indictment,” thereby justifying the sentencing enhancement as a “prohibited person.” The Sixth Circuit held that, under Michigan law, the original felony charge remains pending throughout the diversion program until successful completion or revocation, and no judgment of conviction is entered unless the program is revoked. Consequently, the court affirmed that the defendant was “under indictment” during the relevant period, and thus properly subject to the federal sentencing enhancement. The judgment of the district court was affirmed. View "United States v. Rolon" on Justia Law

A real estate developer purchased a vacant parcel of land in Worthington, Ohio, previously owned by a youth home. The property was primarily zoned for public or institutional uses such as parks, hospitals, and churches. The developer sought to build a mixed-use project and applied for rezoning and development plan approval. After public meetings where concerns about greenspace, traffic, and density were raised, the municipal planning commission tabled the initial application. The developer later reduced the number of proposed residential units, but the commission still declined to recommend approval, and the city council denied the rezoning application. Subsequently, the city amended its comprehensive plan to emphasize greenspace. The developer, having purchased the property after waiving a rezoning contingency, filed suit, alleging constitutional violations due to the city’s refusal to rezone and amend the comprehensive plan.The United States District Court for the Southern District of Ohio dismissed most of the developer’s claims at the motion-to-dismiss stage, including due process counts, and granted summary judgment to the city on the remaining regulatory takings and declaratory judgment claims. The developer appealed, challenging the dismissal and grant of summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the grant of summary judgment and dismissal de novo. The court held that the city’s actions did not constitute a regulatory taking under the Penn Central factors, as the developer lacked a reasonable investment-backed expectation of rezoning approval and the city’s actions had legitimate public purposes. The court also found that the zoning ordinance was not unconstitutional beyond fair debate and that the developer failed to allege a cognizable property interest or arbitrary government action for its due process claims. The Sixth Circuit affirmed the district court’s judgment in all respects. View "Lifestyle Communities, Ltd. v. City of Worthington" on Justia Law

The State of Ohio brought a lawsuit in state court against several pharmacy benefit managers (PBMs) and related entities, alleging they conspired to artificially inflate prescription drug prices in violation of Ohio law. Ohio claimed that the PBMs, acting as intermediaries between drug manufacturers and health plans, negotiated rebates and fees in a manner that increased drug list prices and extracted payments from pharmacies, harming consumers and violating state antitrust and consumer protection statutes. The PBMs provided services to both private clients and federal health plans, including those for federal employees and military personnel.The defendants, Express Scripts and Prime Therapeutics, removed the case to the United States District Court for the Southern District of Ohio under the federal officer removal statute, arguing that their negotiations on drug prices were conducted on behalf of both federal and non-federal clients in a unified process subject to federal oversight. Ohio moved to remand the case to state court, asserting that its claims did not target conduct directed by federal officers and disclaimed any challenge to the administration of federal health programs like FEHBA or TRICARE. The district court accepted Ohio’s disclaimer and determined that the complaint did not impose liability for acts under federal direction, granting Ohio’s motion to remand.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the matter de novo. The court held that the PBMs were “persons acting under” federal officers because their negotiations were performed under detailed federal supervision and regulation for federal health plans. The court further found that the complaint related to acts under color of federal office, as the alleged wrongful conduct was inseparable from federally directed negotiations. The court also determined that the PBMs raised colorable federal defenses based on federal preemption. Consequently, the Sixth Circuit reversed the district court’s remand order and remanded the case for further proceedings in federal court. View "Ohio ex rel. Yost v. Ascent Health Services, LLC" on Justia Law

Joshua Steeb was severely injured after intervening to save his friend, Teresa Fitzgerald, from a violent dog attack at the home of Linda Motter, Fitzgerald’s relative. The dog, known for its aggressive history and previously quarantined by local authorities, was reported to animal control for removal. Officer Mike Ehart, aware of the dog’s past behavior, arrived on the scene but instead of personally handling the dog, he instructed Fitzgerald to retrieve and secure the animal in his truck. Despite Fitzgerald’s apprehension and knowledge of the dog’s dangerous tendencies, she attempted the task and was attacked. Steeb’s attempt to rescue her resulted in the dog mauling him, causing permanent injuries.The United States District Court for the Western District of Michigan reviewed Steeb’s claims under 42 U.S.C. § 1983, which were based on the “state-created-danger” theory of substantive due process. Steeb argued that Officer Ehart’s conduct created or increased the risk that led to the attack and that the City of Battle Creek failed to properly train and equip Ehart. The district court dismissed all federal claims, finding that Steeb had not alleged a plausible constitutional violation. As a result, the court declined to exercise jurisdiction over the related state law claims, dismissing them without prejudice.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The appellate court held that Steeb failed to plausibly allege that Officer Ehart took an “affirmative act” sufficient to invoke the state-created-danger doctrine, primarily because Fitzgerald voluntarily assumed the risk of handling the dangerous dog. Without a constitutional violation, the municipal liability claim against the City of Battle Creek also failed. The appellate court thus affirmed the dismissal of Steeb’s claims. View "Steeb v. Ehart" on Justia Law

An individual seeking to refinance his mortgage visited a website that offers mortgage information and referrals to affiliated lenders. During three separate visits, he entered personal information and clicked buttons labeled “Calculate” or “Calculate your FREE results.” Immediately below these buttons, the website displayed language in small font stating that clicking would constitute consent to the site’s Terms of Use, which included a mandatory arbitration provision and permission to be contacted by the site or affiliates. The Terms of Use were accessible via a hyperlinked phrase. After using the site, the individual was matched with a particular lender but did not pursue refinancing. Later, he received multiple unwanted calls from the lender and filed a class-action lawsuit under the Telephone Consumer Protection Act, alleging violations such as calling numbers on the Do Not Call registry.The United States District Court for the Eastern District of Michigan initially dismissed the complaint on the merits and denied the lender’s motion to compel arbitration as moot. Upon realizing the arbitration issue should have been decided first, the court reopened the case but found no enforceable agreement to arbitrate existed, denying the motion to compel arbitration. The court also denied reconsideration and allowed the plaintiff to amend his complaint. The lender appealed the denial of arbitration.The United States Court of Appeals for the Sixth Circuit reviewed the denial de novo. It held that, under California law, the website provided reasonably conspicuous notice that clicking the buttons would signify assent to the Terms of Use, including arbitration. The court found that the plaintiff’s conduct objectively manifested acceptance of the offer, forming a binding arbitration agreement. The court also concluded that the agreement was not invalid due to unspecified procedural details and that questions of arbitrability were delegated to the arbitrator. The Sixth Circuit reversed the district court’s decision and remanded for further proceedings. View "Dahdah v. Rocket Mortgage, LLC" on Justia Law

A Kentucky citizen who is subject to lifetime sex offender registration due to prior convictions challenged a new state law requiring certain sex offenders to display their full legal names on social media accounts they create or control. The law defines covered offenses as those committed against minors and applies to a wide range of social media platforms, with exceptions for services such as email and search engines. The plaintiff, who uses social media anonymously for personal and political expression, alleged that the law’s disclosure requirement would subject him and his family to harassment and would force him to stop using social media.The United States District Court for the Western District of Kentucky reviewed the case. Initially, it found the plaintiff was likely to succeed on his claim that the law infringed his First Amendment right to post anonymously and was overbroad, granting a preliminary injunction that barred all Kentucky County Attorneys from enforcing the law. The court later denied class certification, concluding the plaintiff lacked standing to represent absent class members against other County Attorneys and failed to meet requirements for class actions. Consequently, the injunction was narrowed to apply only to the named defendant and protect only the plaintiff.On appeal, the United States Court of Appeals for the Sixth Circuit found the district court erred in its facial overbreadth analysis. The Sixth Circuit held that a proper facial challenge under the First Amendment requires a comprehensive review of the law’s scope and its constitutional and unconstitutional applications, as described in Moody v. NetChoice, LLC. The district court had failed to conduct this thorough analysis and focused too narrowly on the plaintiff’s own circumstances. The Sixth Circuit vacated the preliminary injunction and remanded the case for further proceedings consistent with the proper two-step facial overbreadth approach. View "Doe v. Burlew" on Justia Law

Louis Alford was stopped by Cannon County Sheriff’s Deputies outside Woodbury, Tennessee for minor traffic violations. During the stop, Deputy Deffendoll observed a syringe filled with clear liquid inside Alford’s truck. A subsequent search revealed additional empty syringes, powder in a baggie, paper with residue, empty baggies, prescription pills not belonging to either occupant, and digital scales. Alford was arrested and charged with three state drug offenses. He spent time in jail, and his parole was revoked, resulting in over a year in prison. The drug charges were later dismissed. Forensic analysis showed the powder contained methamphetamine, but other items either contained noncontrolled substances or were not tested.Alford filed suit in the United States District Court for the Middle District of Tennessee against Deputies Deffendoll and Smith, and Cannon County, asserting false arrest, malicious prosecution, and Monell liability under 42 U.S.C. § 1983. After discovery, the district court granted summary judgment to the defendants on the federal claims, finding no genuine issue of material fact as to Smith’s involvement, and that Deffendoll had probable cause for arrest and prosecution. The court also rejected the Monell claim, finding no underlying constitutional deprivation. Alford appealed only the federal claims.On review, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The court held that Smith was not personally involved in the arrest, and Deffendoll had probable cause to arrest and charge Alford for simple possession and possession of drug paraphernalia. The court applied the proper summary judgment and qualified immunity standards, and clarified that probable cause existed for the charges that led to Alford’s seizure. Without a constitutional violation, Alford’s Monell claim failed. The court affirmed summary judgment for all defendants. View "Alford v. Deffendoll" on Justia Law

After receiving an anonymous tip, law enforcement in Mercer County, Kentucky, stopped Steven Fellmy, who was driving a silver Ford Mustang matching the tip’s description. The stop was based on observed traffic violations, including a non-illuminated license plate and failure to signal a turn. After backup arrived, Fellmy was asked to exit the vehicle. He declined consent for a search, so a trained drug dog was led around the car. The dog briefly jumped up onto the car door and partially sniffed through the open window, ultimately alerting officers to drugs. A subsequent search revealed methamphetamine and heroin, leading to Fellmy’s arrest and charge for possession of methamphetamine with intent to distribute.The United States District Court for the Eastern District of Kentucky reviewed and denied Fellmy’s pretrial motion to suppress the drugs. The court found that officers lawfully ordered Fellmy out of the vehicle after a valid traffic stop and that the dog’s actions did not constitute an unlawful search because the officers did not encourage the dog to intrude into the car’s interior. The court also denied Fellmy’s motion in limine to exclude the drug evidence, ruling that concerns about authentication and chain of custody went to the weight of the evidence, not its admissibility, and could be addressed during cross-examination. The drugs were admitted, and Fellmy was convicted by jury and sentenced to 300 months’ imprisonment.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The Sixth Circuit held that ordering Fellmy out of the car after a valid stop was lawful and that the dog’s brief contact with the car did not amount to a Fourth Amendment search under prevailing legal standards. The court also held that the district court did not abuse its discretion in admitting the drug evidence or in denying an evidentiary hearing regarding the chain of custody. The conviction and sentence were affirmed. View "United States v. Fellmy" on Justia Law

Michael Victor was detained overnight in an Otsego County, Michigan jail after being arrested for disorderly conduct and resisting an officer. Victor, who has epilepsy, did not receive his prescribed anti-seizure medication while in custody, despite his mother delivering it to the jail and officers being informed of his medical needs. The jail’s procedures required officers to contact an on-call medical provider from Advanced Correctional Healthcare (ACH) before administering any medication. After his release the next morning, Victor suffered a seizure, resulting in significant injuries.The United States District Court for the Eastern District of Michigan heard Victor’s civil rights suit against ACH and Nurse Kimberly Reynolds. At trial, Victor presented evidence including testimony from officers and medical staff, but no one recalled making or receiving a call to ACH regarding his medication, and no records indicated any such contact. The jury found in favor of Reynolds but against ACH, awarding Victor economic, noneconomic, and punitive damages. ACH moved for judgment as a matter of law or a new trial, arguing insufficient evidence that any officer contacted ACH. The district court granted ACH’s motions, holding there was not enough evidence for a reasonable jury to find that contact occurred, and also denied Victor’s request for sanctions related to alleged discovery violations.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Victor had presented sufficient evidence to allow a reasonable jury to find that an officer had contacted ACH about his medication needs. The court held that the absence of any records and the lack of recollection from all involved witnesses meant Victor had not met his burden. Testimony indicating intent to call, without corroboration, was not enough. The Sixth Circuit affirmed the district court’s judgment as a matter of law for ACH and found no abuse of discretion in denying sanctions. View "Victor v. Reynolds" on Justia Law