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

Glorianna Moore was stopped by Officer Brian Wilson for speeding in Pontiac, Michigan. When Moore refused to show her license and moved her hands towards the center console, Wilson reached into her car, grabbed her arm, and ordered her to shut off the car. Moore resisted by screaming and twisting her body. Wilson restrained her by holding her arm and head until backup arrived. Moore was subsequently handcuffed and placed in Wilson's patrol car. Although an initial test indicated the presence of cocaine in Moore's car, further testing revealed it was not cocaine, leading to the dismissal of all charges against her.Moore filed a § 1983 action against Wilson and other officers, alleging excessive force in violation of her Fourth Amendment rights. The United States District Court for the Eastern District of Michigan granted summary judgment to all defendants except Wilson, who appealed the denial of his motion for summary judgment based on qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Officer Wilson did not violate clearly established Fourth Amendment principles. The court reasoned that Wilson's actions were reasonable given Moore's refusal to show her license, her movement towards the center console, and her active resistance. The court concluded that no clearly established law indicated that Wilson's use of force was excessive under the circumstances, thus entitling him to qualified immunity. View "Moore v. Oakland County" on Justia Law

Megan Miller was arrested and booked into the City of Troy’s pretrial detention facility, where she informed staff that she had been heavily using heroin and expected to go into withdrawal. Over the next two and a half days, Miller vomited continually. On the third day, she was found unconscious and unresponsive in her cell and was pronounced dead shortly after. Despite her continual vomiting, no jail official sought medical care for her, including Julie Green-Hernandez, who was responsible for monitoring detainees on the day of Miller’s death. Miller’s husband sued Green-Hernandez, claiming she violated Miller’s Fourteenth Amendment right to adequate pretrial medical care and acted with gross negligence under Michigan state law.The United States District Court for the Eastern District of Michigan denied Green-Hernandez’s motion for summary judgment, concluding she was not entitled to qualified immunity on the Fourteenth Amendment claim or state law immunity on the negligence claim. The court found that there were disputes of material fact regarding whether Green-Hernandez was deliberately indifferent to Miller’s serious medical needs and whether her conduct amounted to gross negligence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Green-Hernandez’s appeal regarding qualified immunity due to lack of jurisdiction, as her arguments were based on factual disputes rather than purely legal questions. However, the court reversed the district court’s denial of Michigan governmental immunity. The Sixth Circuit held that while Green-Hernandez’s conduct could be considered grossly negligent, it was not the single most proximate cause of Miller’s death. The court concluded that Miller’s ingestion of fentanyl was the most immediate, efficient, and direct cause of her death, entitling Green-Hernandez to state law immunity. The case was remanded for further proceedings consistent with this opinion. View "Gillman v. City of Troy" on Justia Law

Michael and Rebecca McIntosh owned a mobile home park in Madisonville, Kentucky. In 2020, a tenant complained about mold and mildew in one of the mobile homes. The City of Madisonville inspected the home and found it unsafe, condemning it and giving the McIntoshes 30 days to submit repair plans. The McIntoshes disputed the condemnation, claiming they made necessary repairs and attempted to contact city officials multiple times without success. The City demolished the mobile home a month later.The McIntoshes pursued a § 1983 action, alleging due process violations. The district court granted summary judgment in favor of the City, leading the McIntoshes to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that while the City provided adequate notice of the condemnation, it failed to provide the McIntoshes with a pre-demolition hearing, as required by due process. The court noted that the City’s Code promised a hearing before a Local Appeals Board, which did not exist. The court also found that informal opportunities for a hearing were not adequately communicated to the McIntoshes. However, the court upheld the district court’s decision on the substantive due process claim, stating that the City’s actions did not rise to the level of conscience-shocking behavior. The court reversed the district court’s summary judgment on the procedural due process claim and affirmed the decision on the substantive due process claim, remanding the case for further proceedings on the procedural due process claim. View "McIntosh v. City of Madisonville" on Justia Law

The case involves a Chapter 11, Subchapter V debtor, Human Housing Henrietta Hyatt, LLC, whose owners and a related third-party, Clearview Eastern Fund, LLC, appealed orders approving the sale of the debtor’s real property. The confirmed plan allowed the plan trustee wide discretion in conducting the sale. The owners did not participate meaningfully in the sale proceedings, and Clearview, a competing bidder, lacked standing to appeal the orders as it did not preserve its appeal rights and failed to obtain a stay of the sale orders.The United States Bankruptcy Court for the Western District of Kentucky approved the sale of the debtor’s real property. The bankruptcy court found that the buyers were purchasing the properties in good faith and entitled to the protections of 11 U.S.C. § 363(m). Clearview filed a motion for reconsideration and a motion for a stay pending appeal, both of which were denied by the bankruptcy court. Clearview then filed an affidavit claiming pre-existing purchase contracts, but this was not timely presented to the bankruptcy court.The Bankruptcy Appellate Panel of the Sixth Circuit reviewed the case. The panel determined that the appellants were limited on appeal to challenging the purchasers’ good faith due to the mootness rule codified in 11 U.S.C. § 363(m). The panel found that the appellants had waived their arguments on appeal by not raising them in the bankruptcy court proceedings. The panel affirmed the bankruptcy court’s orders approving the sale of the debtor’s assets and the orders denying the motion for reconsideration and the motion for a stay pending appeal. The panel also affirmed the orders approving compensation for the real estate broker, as the appellants had not objected to the compensation applications in the bankruptcy court. View "In re Human Housing Henrietta Hyatt, LLC" on Justia Law

Dayton Power & Light Company, along with other utilities, sought an RTO adder from the Federal Energy Regulatory Commission (FERC) as an incentive for joining a Regional Transmission Organization (RTO). Ohio law mandates that utilities join an RTO, which led FERC to deny Dayton Power's application, arguing that the adder is meant to incentivize voluntary actions, not those required by law. The Ohio Consumers’ Counsel (OCC) challenged the existing RTO adders for other Ohio utilities, leading FERC to remove the adder for AEP but not for Duke and FirstEnergy, citing the latter's comprehensive settlement agreements.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court first addressed whether the utilities could challenge the voluntariness requirement of Order 679, concluding that they could because FERC's past practices did not clearly indicate a strict voluntariness requirement. The court then interpreted Section 219(c) of the Federal Power Act, agreeing with FERC that the best reading of the statute supports the requirement that RTO membership must be voluntary to qualify for the adder.The court also considered the utilities' preemption argument, which claimed that federal law should override Ohio's mandate for RTO membership. The court held that the Federal Power Act does not preempt Ohio law, as Congress did not intend to prevent states from mandating RTO participation, especially when such mandates align with federal goals of increasing RTO membership.Finally, the court found FERC's differential treatment of AEP, Duke, and FirstEnergy to be arbitrary and capricious. It noted that all three utilities' rates included a 50-basis-point RTO adder, whether explicitly approved or impliedly included in settlements. The court affirmed FERC's denial of Dayton Power's application and the removal of AEP's adder but reversed the decision to retain the adders for Duke and FirstEnergy, remanding for further proceedings. View "Dayton Power & Light Co. v. Federal Energy Regulatory Commission" on Justia Law

The case involves Michigan's electricity market regulations, specifically the Individual Local Clearing Requirement (ILCR), which mandates that electricity retailers in Michigan's lower peninsula procure a certain percentage of their capacity from within that region. Plaintiffs, including Energy Michigan and the Association of Businesses Advocating Tariff Equity (ABATE), challenged the ILCR on the grounds that it violates the dormant Commerce Clause by discriminating against interstate commerce.The United States District Court for the Eastern District of Michigan initially dismissed the Michigan Public Service Commission (MPSC) on Eleventh Amendment grounds but allowed the case to proceed against individual commissioners. The court denied summary judgment motions from both sides, finding that there were factual disputes regarding whether the ILCR discriminated against interstate commerce. After a three-day bench trial, the district court concluded that the ILCR did not violate the Commerce Clause.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the ILCR is facially discriminatory because it requires electricity to be generated within a specific geographic region, effectively favoring in-state over out-of-state electricity. The court held that this discrimination necessitates strict scrutiny, which the district court did not properly apply. The Sixth Circuit reversed the district court's judgment and remanded the case for further proceedings to determine if the ILCR can survive strict scrutiny by proving it is the only means to achieve the state's goal of ensuring a reliable energy supply. View "Energy Michigan, Inc. v. Public Service Commission" on Justia Law

Zillow, Inc., a for-profit corporation, requested property tax data from several Kentucky property valuation administrators (PVAs) under Kentucky’s Open Records Act (KORA). The PVAs classified Zillow’s requests as having a commercial purpose and quoted fees amounting to thousands of dollars. Zillow sued, arguing that KORA’s fee structure, which distinguishes between commercial and non-commercial purposes and includes exceptions for newspapers, radio, and television stations, violated the First and Fourteenth Amendments.The United States District Court for the Eastern District of Kentucky held that the commercial/non-commercial distinction did not violate the First or Fourteenth Amendments but found the newspaper exception unconstitutional. The court severed the newspaper exception from the statute, resulting in both Zillow and newspapers being subject to enhanced fees. The Kentucky Press Association and American City Business Journals intervened and, along with Zillow, appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the commercial-fee statute did not violate the First Amendment as applied to Zillow. It determined that the distinction between commercial and non-commercial purposes was content-neutral and did not impermissibly discriminate based on the content of Zillow’s speech. The court reversed the district court’s order declaring the newspaper exception unconstitutional, vacated the permanent injunction, and remanded with instructions to grant summary judgment to the PVAs. View "Zillow, Inc. v. Miller" on Justia Law

Shawn Lamar Peake-Wright, Jr. was a passenger in a car driven by Kimberly Manney in Kalamazoo, Michigan, when they were stopped by Sgt. Timothy Millard. Sgt. Millard recognized Peake-Wright and knew of his criminal history. During the stop, Peake-Wright exhibited strange behavior, including removing his jacket in freezing weather and repeatedly standing up despite officers' instructions to remain seated. Sgt. Millard, suspecting that Peake-Wright's jacket might contain contraband, searched it and found a loaded 9mm pistol.The United States District Court for the Western District of Michigan denied Peake-Wright's motion to suppress the evidence of the firearm, holding that the search was justified under the automobile exception to the warrant requirement. The court found that Peake-Wright's behavior and criminal history provided probable cause to believe that his jacket contained evidence of a crime.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the duration of the traffic stop was reasonable and that the officers had probable cause to search Peake-Wright's jacket. The court emphasized that the totality of the circumstances, including Peake-Wright's erratic behavior and criminal history, justified the search under the automobile exception. The court concluded that the search was lawful and upheld the district court's judgment. View "United States v. Peake-Wright" on Justia Law

Michael Mills was convicted of being a felon in possession of ammunition after a shootout involving members of the Detroit gang, It’s Just Us (IJU). Mills, armed with a loaded pistol-grip shotgun, fired two shots during the altercation, resulting in the death of IJU member James Matthews Jr. Mills was subsequently arrested and charged. A jury found him guilty, and the district court sentenced him to the statutory maximum of 120 months, applying a sentencing enhancement based on Mills's role in Matthews's death.The United States District Court for the Eastern District of Michigan initially sentenced Mills, but the case was remanded by the United States Court of Appeals for the Sixth Circuit for additional factual findings regarding the sentencing enhancement. On remand, the district court reaffirmed its findings, concluding that Mills caused Matthews's death, had the necessary mental state for second-degree murder, and rejected Mills's justification defense. The district court reimposed the same 120-month sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case again. The court held that the district court did not clearly err in finding that Mills committed second-degree murder with malice aforethought, based on his actions and social media messages indicating a premeditated intent. The court also found no clear error in the district court's rejection of Mills's justification defense, noting that Mills had viable alternatives to engaging in the shootout. Additionally, the appellate court determined that the district court properly considered the sentencing factors, including the need for deterrence and Mills's criminal history.The Sixth Circuit affirmed the district court's judgment, upholding Mills's 120-month sentence. View "United States v. Mills" on Justia Law

Mateo Alexander Mateo-Esteban and his father, Montejo, natives of Guatemala, entered the United States illegally in 2015. Mateo-Esteban applied for asylum, withholding of removal, and protection under the Convention against Torture (CAT). The Department of Homeland Security (DHS) served both with notices to appear, and they were ordered removed in absentia after failing to attend their hearing. The Board of Immigration Appeals (BIA) later reopened the case. At the reopened hearing, Montejo testified about gang extortion and threats in Guatemala, leading to their flight to the U.S.The Immigration Judge (IJ) denied Mateo-Esteban’s application, finding that his proposed social group, “people who are afraid of gangs in Guatemala,” was not legally cognizable and that he failed to demonstrate that the Guatemalan government would acquiesce in his torture if he returned. The IJ also found Montejo’s testimony lacked credibility and noted that they could have relocated within Guatemala or that Mateo-Esteban could have lived with his mother. The BIA affirmed the IJ’s decision, agreeing that the proposed social group was not cognizable and that there was no likelihood of government acquiescence in torture.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Mateo-Esteban’s proposed social group was not legally cognizable, as it lacked particularity and social distinction. The court also found that the evidence did not compel the conclusion that the Guatemalan government would acquiesce in Mateo-Esteban’s torture. The court noted that the Guatemalan government had made efforts to combat gang violence and police corruption. Consequently, the Sixth Circuit denied Mateo-Esteban’s petition for review. View "Mateo-Esteban v. Garland" on Justia Law