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

A Kentucky-based manufacturer entered into a sales representative agreement with a Minnesota-based company to facilitate sales of industrial parts in several Midwestern states. The contract included a choice of law clause specifying Kentucky law would govern disputes and permitted the manufacturer to terminate the relationship at its discretion. However, a pre-contract email from Minnesota’s representatives revealed their intent to disregard the Kentucky choice of law, planning instead to invoke the Minnesota Termination of Sales Representatives Act (MTSRA), which restricts termination and invalidates conflicting contract terms.After several years, the manufacturer issued a termination notice in line with the contract. The Minnesota company, shortly before the contract’s automatic renewal, claimed protection under the MTSRA and demanded $165,000, threatening litigation. The manufacturer responded by filing suit in the United States District Court for the Eastern District of Kentucky, seeking declaratory judgment that Kentucky law governed and asserting fraudulent inducement based on the Minnesota company’s misrepresentation of its intent to abide by the choice of law provision.The district court held that Kentucky law applied, rendering the MTSRA inapplicable, and granted declaratory judgment for the manufacturer. It permitted the fraudulent inducement claim to proceed to a jury, which found the Minnesota company liable, awarding nominal actual damages and $280,000 in punitive damages. The court denied post-trial motions challenging the verdict, jury instructions, evidentiary rulings, and the punitive damages award.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The Sixth Circuit held that Kentucky’s choice of law rules applied and that Kentucky had the most significant relationship to the contract, making the MTSRA inapplicable. The court upheld the jury’s finding of fraudulent inducement and found no abuse of discretion in the district court’s management of trial issues. The punitive damages award was found not to violate due process. View "Bonfiglioli USA, Inc. v. Midwest Engineered Components, Inc." on Justia Law

Three individuals—Khari, Logan, and Saruba—became involved in a drug distribution scheme. While incarcerated, Khari connected his cellmate (who was cooperating with law enforcement) with Logan, a drug dealer based in Detroit but residing in Lexington, Kentucky. Logan, guided by Khari, communicated with an undercover officer and arranged to sell fentanyl and methamphetamine. Saruba, Logan’s girlfriend, accompanied Logan to a drug deal and participated in the exchange. Law enforcement recorded and monitored the transactions, conducted controlled buys, and eventually arrested the trio after seizing large quantities of drugs and drug paraphernalia.The United States District Court for the Eastern District of Kentucky presided over the proceedings. Logan pleaded guilty to conspiracy and possession with intent to distribute, receiving a 360-month sentence. Khari and Saruba proceeded to trial. The jury convicted both of aiding and abetting drug distribution; Khari was also convicted of using a telephone to facilitate a drug offense, while Saruba was acquitted of conspiracy. The district court sentenced Khari to 150 months, consecutive to a prior sentence, and Saruba to 92 months.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed multiple challenges. The court rejected Logan’s claims of procedural and substantive sentencing error and affirmed her conviction and sentence. Khari’s sufficiency-of-the-evidence and sentencing arguments were also rejected, with the court upholding his conviction and sentence. For Saruba, the court affirmed her conviction, finding no reversible error in her trial or in the sufficiency of evidence. However, the appellate court determined that the district court erred by failing to apply a two-level reduction to her offense level under the Sentencing Guidelines. As a result, the Sixth Circuit vacated Saruba’s sentence and remanded her case for resentencing. View "United States v. Smith" on Justia Law

A native and citizen of Guatemala, the petitioner entered the United States in 2007 after fleeing an intrafamilial land dispute in which his great uncle, motivated by a conflict over inheritance and, to a lesser extent, political differences, threatened his family. In 2011, he was stopped by an Ohio police officer for littering. The officer suspected him of possessing false identification and obstructing official business, leading the Department of Homeland Security to initiate removal proceedings. The petitioner conceded removability but sought relief on several grounds, arguing that his stop was racially motivated, and that his removal would expose him to persecution or torture in Guatemala due to his membership in particular social groups or political opinions.An Immigration Judge denied the petitioner’s motion to suppress evidence, finding no constitutional or regulatory violations, and rejected his applications for asylum, withholding of removal, and protection under the Convention Against Torture (CAT). The judge determined the asylum application was time-barred and, on the merits, found no nexus between the alleged harm and any protected ground. The judge also found insufficient evidence of likely torture upon return to Guatemala. The petitioner appealed to the Board of Immigration Appeals (BIA), which affirmed the Immigration Judge’s decisions and denied as untimely his later motion to terminate or remand the proceedings based on alleged defects in his notice to appear.The United States Court of Appeals for the Sixth Circuit reviewed the BIA’s final order. The court held that the denial of the motion to suppress was proper because the initial stop was supported by reasonable suspicion, and no egregious Fourth Amendment violation occurred. The court further held that the petitioner’s claims-processing challenge to the notice to appear was untimely, and substantial evidence supported the findings that there was no nexus for withholding of removal and no likelihood of torture for CAT relief. The petition for review was denied. View "Perez-Hernandez v. Blanche" on Justia Law

The defendant was arrested in 2023 after police discovered evidence linking him to significant drug trafficking, including large quantities of fentanyl and methamphetamine, as well as a firearm. He confessed to both personal use and substantial sales of fentanyl. Previously, he had two state felony convictions for possessing meth for resale, served five years in prison, and was paroled before committing the new offense. A federal grand jury charged him with several offenses, but he ultimately pleaded guilty to possessing with intent to distribute at least 40 grams of a fentanyl mixture. The government dismissed other charges and did not pursue enhanced penalties.The United States District Court for the Eastern District of Tennessee sentenced the defendant as a career offender, calculating a Guidelines range of 188 to 235 months and imposing a sentence at the lower end. The defendant moved for a downward variance, arguing that his prior state convictions should not qualify him as a career offender under the guidelines, citing his upbringing and the time gap between convictions as mitigating factors. He also challenged the inclusion of state-law convictions as career-offender predicates, suggesting the Sentencing Commission exceeded its statutory authority. The district court considered his mitigating arguments but denied the variance and applied the guideline.The United States Court of Appeals for the Sixth Circuit reviewed the sentence. It held that the career-offender guideline validly includes state-law convictions, interpreting the statute to cover offenses “described in” federal drug statutes, regardless of whether the convictions were under federal or state law. The court found no procedural error, as the district court adequately considered the relevant factors and explained its reasoning. The court also found the sentence substantively reasonable, especially as it was within the Guidelines range, and rejected the defendant’s challenges. Accordingly, the Sixth Circuit affirmed the sentence. View "United States v. King" on Justia Law

A dispute arose between two former spouses involving child custody and related issues in Ohio state court. After their 2019 divorce, they shared parenting responsibilities for their two children. In 2023, the ex-husband, a police officer, allegedly enlisted a county employee to access confidential information about his ex-wife’s fiancé, and this information was subsequently shared. Complaints about this conduct were filed with municipal and county authorities. Amid these events, the ex-wife and her fiancé filed a federal lawsuit alleging violations of federal civil rights statutes and state law, and sought relief against municipal and county entities.In the United States District Court for the Southern District of Ohio, the plaintiffs amended their complaint and the City of Cincinnati moved to dismiss the claims against it. The district court dismissed these claims under Monell v. Department of Social Services. The plaintiffs sought reconsideration or, alternatively, certification to appeal the dismissal, but the district court declined to certify the order as final. Separately, the ex-wife moved for a temporary restraining order and preliminary injunction to prevent enforcement of an Ohio state court’s contempt order, which sanctioned her for disclosing the ex-husband’s address in federal filings. The district court denied injunctive relief, citing Younger v. Harris abstention, to avoid interference with ongoing state court proceedings.The United States Court of Appeals for the Sixth Circuit reviewed two issues: the district court’s abstention from granting injunctive relief and the dismissal of the Monell claim. The Sixth Circuit held that Younger abstention was appropriate because the contempt proceeding was an ongoing state judicial process implicating important state interests, and the plaintiff had an adequate opportunity to raise constitutional challenges in state court. The court also determined it lacked appellate jurisdiction over the Monell dismissal, as the district court’s order was not final and had not been certified for interlocutory appeal. The court affirmed the abstention and dismissed the Monell appeal for lack of jurisdiction. View "Taylor v. Hooven" on Justia Law

A hospice provider participated in the Medicare program and sought reimbursement for hospice services provided to several patients. Medicare, through its contractor, conducted a review and determined that a substantial number of the provider's claims did not meet the required coverage criteria, resulting in a demand for repayment of nearly $1 million. The contractor’s decision was partially reversed at the next level of administrative review for some claims, but a significant number were still denied. The provider pursued further administrative appeals, including a hearing before an administrative law judge (ALJ), where testimony and medical records were considered. The ALJ ultimately found that some additional claims were covered but upheld the denial of coverage for others, concluding that the provider was financially responsible for those denied claims and could not benefit from the statutory safe harbor.After the Medicare Appeals Council failed to resolve the provider’s appeal within the prescribed time, the provider sought judicial review in the United States District Court for the Northern District of Ohio. The district court affirmed the ALJ’s decision, agreeing with the denial of coverage for the disputed claims and with the determination that the provider was not entitled to the safe harbor protection.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed two issues: whether substantial evidence supported the ALJ’s denial of Medicare coverage for the claims, and whether the ALJ properly applied the Medicare statute’s safe harbor provision. The appellate court held that substantial evidence did support the denial of coverage. However, it determined that the ALJ had applied the wrong legal standard to the safe harbor inquiry. The Sixth Circuit clarified that the correct standard requires assessment of whether the provider reasonably interpreted the relevant Medicare guidance as covering the disputed claims. The court vacated the district court’s judgment as to the safe harbor issue and remanded with instructions to return the case to the ALJ for application of the correct safe harbor standard to each disputed claim. View "In Home Health, LLC v. Kennedy" on Justia Law

Christopher Hemwall was convicted by a jury in Michigan of multiple counts of criminal sexual conduct involving his twin half-sisters, with the incidents occurring when the victims were between four and six years old. The offenses took place from 2005 to 2008 and were reported to authorities roughly a decade later. Following his conviction, Hemwall received a lengthy prison sentence. He exhausted his appellate rights, with the Michigan Court of Appeals affirming his conviction and the Michigan Supreme Court denying leave to appeal. Hemwall did not pursue review by the U.S. Supreme Court, and his convictions became final in August 2021.Hemwall sought post-conviction relief in Michigan courts, alleging ineffective assistance of counsel. The Monroe County Circuit Court denied his motion, the Michigan Court of Appeals declined leave to appeal, and the Michigan Supreme Court denied leave in January 2024. Hemwall then filed a federal habeas petition under 28 U.S.C. § 2254 in the United States District Court for the Eastern District of Michigan, but it was filed nearly three months after the statutory deadline. Hemwall requested equitable tolling of the one-year statute of limitations, citing his attorney’s health issues and those of the attorney’s child, as well as COVID-19-related disruptions. The district court dismissed the petition, finding Hemwall failed to establish that these circumstances caused the late filing, but granted a certificate of appealability due to unsettled precedent.The United States Court of Appeals for the Sixth Circuit reviewed the case. It assumed for argument’s sake that the attorney’s health difficulties could qualify as extraordinary circumstances but held that Hemwall did not prove these difficulties caused the late filing. The Sixth Circuit found no clear error in the district court’s factual finding that the attorney’s personal issues did not prevent timely filing, especially given evidence that the attorney was able to continue practicing law and that the federal petition was largely copied from prior state filings. The court affirmed the district court’s dismissal of Hemwall’s habeas petition. View "Hemwall v. Douglas" on Justia Law

The case concerns a defendant who was arrested after his girlfriend reported to police that he had struck her, taken her handgun, chambered a round, and threatened her with it. Forensic evidence later confirmed his DNA on the weapon. The defendant gave conflicting accounts, initially denying knowledge of the gun, then claiming he took it from his girlfriend to protect himself. Officers arrested him, and he was charged in state court with domestic violence and illegal firearm possession. While out on bond, federal prosecutors indicted him for being a felon in possession of a firearm after an earlier felony conviction. During execution of a federal arrest warrant, officers found a stolen rifle in the home. The government offered a plea deal involving a single count, which the defendant declined, resulting in a superseding indictment on two counts.The United States District Court for the Northern District of Ohio denied the defendant’s motion to suppress the rifle and his motion to dismiss on Second Amendment grounds. The defendant ultimately pleaded guilty to both counts without a written plea agreement. At sentencing, the district court applied an enhancement for possessing a firearm in connection with a felony offense, based on evidence that he had threatened his girlfriend with the handgun, and imposed a 100-month prison sentence. The defendant appealed, raising constitutional arguments and challenging the sentencing enhancement.The United States Court of Appeals for the Sixth Circuit held that, because the defendant pleaded guilty unconditionally and did not comply with Federal Rule of Criminal Procedure 11(a)(2), he waived his right to appeal pre-plea constitutional issues. The court declined to address his ineffective assistance of counsel claim on direct appeal, finding the record undeveloped. Reviewing the sentencing enhancement for clear error, the court found ample evidence to support the district court’s application of the enhancement and affirmed the sentence. View "United States v. Williams" on Justia Law

Three defendants, who held leadership positions in a nationwide gang operating in Michigan and Chicago, were charged after a lengthy federal investigation uncovered extensive drug distribution, violent acts, and strict internal codes of silence within the organization. Law enforcement used confidential informants, monitored communications, conducted controlled purchases, and executed search warrants on social media and personal devices to gather evidence. The defendants were indicted for racketeering conspiracy, drug conspiracies, and related offenses. While many co-defendants pled guilty, these three proceeded to trial.The United States District Court for the Eastern District of Michigan conducted a month-long trial, after which a jury convicted all three defendants on most counts. One defendant was acquitted of certain drug trafficking and firearm possession charges but convicted on racketeering, drug conspiracy, and possession with intent to distribute marijuana. At sentencing, the district court imposed lengthy prison terms for each defendant. The defendants appealed, raising suppression issues concerning wiretap evidence, social media searches, and cell phone searches; Sixth Amendment claims regarding prison mail policies and cross-examination limitations; sufficiency-of-the-evidence challenges; and a sentencing dispute.The United States Court of Appeals for the Sixth Circuit reviewed the case. It rejected all suppression arguments except for a procedural sentencing challenge raised by one defendant, finding that the district court failed to adequately address his objection to a sentencing enhancement based on acquitted conduct. The Court affirmed the convictions for all three defendants and rejected their constitutional and evidentiary claims, holding that the evidence and trial procedures met legal standards. However, it vacated the sentence for the one defendant on procedural grounds and remanded for resentencing, while affirming all other aspects of the district court’s judgment. View "United States v. Fordham" on Justia Law

A woman called police to report that her neighbor, Melvin Steger, had stolen her insulin pump after she accidentally dropped it outside her home. Officers responded and spoke to the woman, then approached Steger, who was standing on his own porch behind an iron gate. During the encounter, Steger grew agitated, refused to provide identification, told the officers to get a warrant, and used profanity. After he shouted an obscenity at Officer Willis, Willis immediately slammed the gate into Steger, knocked him down, and punched him twice before handcuffing him. Steger was arrested and charged with several offenses, including disorderly conduct and theft, and was later convicted of theft.Steger subsequently filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Kentucky, alleging that Officers Willis and Appleman used excessive force in violation of the Fourth Amendment. The officers moved for summary judgment on the basis of qualified immunity. The district court denied the motion as to Willis, finding that, based on the record, a reasonable jury could find that Willis’s actions constituted excessive force, which was clearly prohibited by established case law.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity de novo. The appellate court agreed that, accepting the facts in the light most favorable to Steger, Willis’s use of physical force—slamming the gate, knocking Steger down, and punching him twice—against a non-resisting individual on his own porch, without warning and without announcing an arrest, violated clearly established Fourth Amendment rights. The Sixth Circuit affirmed the district court’s denial of qualified immunity to Willis. View "Steger v. Willis" on Justia Law