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

Robert Carbone, a Connecticut resident, sued two Swiss organizations and several individuals from California, Illinois, and Switzerland for defamation and other tortious conduct. Carbone, a member of the two Swiss organizations, claimed that the defendants used websites to publish defamatory statements about him and facilitate his removal from the organizations. He filed the lawsuit in Ohio, arguing that the defamatory statements passed through servers located in Ohio, which hosted the organizations' websites.The United States District Court for the Southern District of Ohio dismissed Carbone's complaint for lack of personal jurisdiction. The court found that Carbone failed to establish that the defendants had sufficient contacts with Ohio to justify the court's jurisdiction over them. The defendants had not purposefully availed themselves of the privilege of acting in Ohio, as the servers' location in Ohio was chosen by third parties, not the defendants.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 defendants did not purposefully avail themselves of the privilege of acting in Ohio, as their only connection to the state was the location of the servers, which was a decision made by third parties. The court also found that Carbone's claims did not arise from the defendants' activities in Ohio, as the allegedly defamatory statements were not directed at Ohio or its residents. Therefore, the exercise of personal jurisdiction over the defendants in Ohio would not comply with the Due Process Clause. View "Carbone v. Kaal" on Justia Law

In 2017, the Saginaw County Sheriff’s Office seized fourteen firearms during a domestic-violence investigation involving Benjamin Heinrich. Heinrich's uncle, Gerald Novak, and distant cousin, Adam Wenzel, claimed ownership of the firearms and sought their return. Sheriff William Federspiel refused to return the firearms, arguing that Novak and Wenzel had not proven ownership. Novak and Wenzel then sued Federspiel under 42 U.S.C. § 1983 and Michigan law, asserting various federal constitutional and state claims.The United States District Court for the Eastern District of Michigan granted summary judgment to Federspiel on all claims and denied Novak and Wenzel’s motion for partial summary judgment. The court found that qualified immunity protected Federspiel in his personal capacity and that Novak and Wenzel had not established constitutional violations. It also held that Michigan law does not recognize a cause of action to sue municipal officials for constitutional torts and that Novak and Wenzel could not establish the elements of claim and delivery.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment to Federspiel on the individual-capacity takings claims, procedural-due-process claims, substantive-due-process claims, Fourth Amendment claims, and inverse-condemnation claims. However, it vacated the grant of summary judgment on the official-capacity and injunctive-relief takings claims, official-capacity Second Amendment claims, and the claim-and-delivery action. The court remanded these claims for further proceedings, noting that Novak and Wenzel’s affidavits created a genuine issue of material fact regarding ownership of the firearms, and that the district court should address whether Federspiel’s actions were consistent with historical firearm regulation. View "Novak v. Federspiel" on Justia Law

Daniel Lockridge, a decorated combat Marine, was involved in methamphetamine trafficking after returning to the U.S. in 2009. He initially used methamphetamine to manage his PTSD and later began selling it, eventually becoming a significant supplier in Chattanooga, Tennessee. Lockridge pleaded guilty to aiding and abetting possession with intent to distribute methamphetamine and was sentenced to 210 months in prison followed by three years of supervised release. His supervised release conditions included mandatory mental-health and substance-abuse treatment, as directed by a probation officer.The United States District Court for the Eastern District of Tennessee imposed these conditions, and Lockridge objected, arguing that the court must preauthorize any inpatient treatment and set a frequency for drug testing, rather than delegating these decisions to a probation officer. The district court overruled his objections, leading to Lockridge's appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not relinquish its authority by not specifying the details of the treatment programs at sentencing. Instead, it retained the discretion to make these decisions closer to the time of Lockridge's supervised release, allowing the probation officer to assess his needs and recommend appropriate treatment. The court emphasized that the ultimate authority to modify or enforce the conditions of supervised release remains with the district court, ensuring compliance with Article III of the U.S. Constitution.The Sixth Circuit affirmed the district court's decision, concluding that the delegation of certain responsibilities to the probation officer did not violate constitutional principles, as the district court retained the final decision-making authority. View "United States v. Lockridge" on Justia Law

Elfido Gonzalez Castillo, a native and citizen of Mexico, illegally entered the United States in 1981 and became a lawful permanent resident in 1989. In 2009, he applied for naturalization but failed to disclose a recent indictment for sexually abusing his niece. He became a naturalized citizen in October 2009 and pleaded guilty to the offense two months later. In 2019, the government sought to revoke his citizenship, and in 2022, a court ordered its cancellation due to his fraudulent procurement. Subsequently, the Department of Homeland Security initiated removal proceedings against him under 8 U.S.C. § 1227(a)(2)(E)(i) for a crime of child abuse.An immigration judge ordered Gonzalez's removal, and the Board of Immigration Appeals upheld this decision. Gonzalez sought review in the Third Circuit, which transferred the case to the Sixth Circuit, determining that venue lay elsewhere.The United States Court of Appeals for the Sixth Circuit reviewed the case and concluded that Gonzalez was not deportable under the child-abuse provision because he was a naturalized citizen at the time of his conviction. The court relied on the precedent set by the Supreme Court in Costello v. INS, which held that deportation provisions do not apply to individuals who were citizens at the time of their conviction. The court noted that the statutory language and the rule of lenity supported this interpretation. Consequently, the Sixth Circuit granted Gonzalez's petition for review, vacated the order of removal, and remanded the case for further proceedings consistent with its opinion. View "Gonzalez Castillo v. Bondi" on Justia Law

A fifty-nine-year-old General Manager (GM) at a Chili’s restaurant in Nashville, Tennessee, was terminated and replaced by a thirty-three-year-old with no managerial experience. The employer, Brinker International, Inc., claimed the termination was due to the GM creating a toxic "culture" and not "living the Chili’s way," despite the restaurant being one of the top performers in the market. The GM alleged that the termination was due to age discrimination, as he was the oldest manager in the region and believed Brinker was systematically replacing older employees with younger ones.The United States District Court for the Middle District of Tennessee granted summary judgment in favor of Brinker, accepting the company's explanation of "culture" as a legitimate, non-discriminatory reason for the termination. The court found that the GM could not sufficiently rebut this explanation to show it was pretext for age discrimination. The court also granted in part and denied in part the GM's motion for sanctions due to Brinker’s spoliation of evidence, awarding fees and costs but not excluding the TMR Report, which documented the termination decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the TMR Report could not be authenticated under Federal Rule of Evidence 901 and was therefore inadmissible. The court vacated the district court’s order on sanctions and instructed it to consider whether additional sanctions beyond fees and costs were appropriate. The appellate court also reversed the district court’s grant of summary judgment for Brinker, finding that the GM had provided sufficient evidence to rebut Brinker’s explanation and create a genuine issue of material fact regarding age discrimination. The court affirmed the district court’s denial of the GM’s motion for summary judgment. View "Kean v. Brinker Int'l, Inc." on Justia Law

From 2016 to 2021, Irene Michelle Fike worked at an accounting firm and later as an independent contractor for a client, J.M., and J.M.'s family. Fike used her access to J.M.'s financial accounts to pay her personal credit card bills and make purchases from online retailers. She concealed her fraud by misrepresenting J.M.'s expenditures in financial reports. Fike defrauded J.M. of $363,657.67 between April 2018 and September 2022.Fike pleaded guilty to wire fraud and aggravated identity theft in 2024. The United States District Court for the Eastern District of Kentucky sentenced her to thirty-six months' imprisonment and three years of supervised release. The court also ordered her to pay $405,867.08 in restitution, which included the principal amount stolen and $42,209.41 in prejudgment interest. Fike appealed, arguing that the Mandatory Victims Restitution Act (MVRA) does not authorize prejudgment interest and that the interest calculation was speculative.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the MVRA allows for prejudgment interest to ensure full compensation for the victim's losses. The court found that the district court did not abuse its discretion in awarding prejudgment interest, as it was necessary to make J.M. whole. The court also determined that the district court had a sufficient basis for calculating the interest, relying on J.M.'s declaration of losses, which was submitted under penalty of perjury and provided a reliable basis for the award. The Sixth Circuit affirmed the district court's decision. View "United States v. Fike" on Justia Law

Fifteen restaurants and bars in Ohio and Florida challenged the Small Business Administration's (SBA) operation of the COVID-19 relief program under the American Rescue Plan Act of 2021 (ARPA). The plaintiffs argued that the SBA did not process their applications for the Restaurant Revitalization Fund (RRF) in the order received, as required by law, and that the SBA failed to recover improperly awarded funds. They sought an injunction to prevent the SBA from closing the RRF until all applications were adjudicated and improperly awarded funds were returned and redistributed.The United States District Court for the Northern District of Ohio dismissed the case for lack of subject-matter jurisdiction and failure to state a claim. The court held that the plaintiffs lacked standing to request enforcement actions to recover RRF grants and that the case was moot because the covered period for using the funds had ended, and Congress had rescinded unobligated funds.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 case was moot because the RRF program expired on March 11, 2023, and any awarded funds could no longer be used by the plaintiffs. The court concluded that even if the plaintiffs were awarded grants, they would be required to return the funds to the Treasury, rendering any court decision ineffectual. The court did not address the SBA's additional arguments regarding standing or mootness, as the expiration of the covered period was sufficient to moot the case. View "W6 Restaurant Group, Ltd v. Loeffler" on Justia Law

The case involves a class action lawsuit filed by Albert Pickett, Jr., Keyonna Johnson, Jarome Montgomery, Odessa Parks, and Tiniya Shepherd against the City of Cleveland. The plaintiffs, all African American residents of Cuyahoga County, Ohio, allege that Cleveland Water's policy of placing water liens on properties for unpaid water bills disproportionately affects Black homeowners. The water liens, which accumulate penalties and interest, can lead to foreclosure and eviction. The plaintiffs claim that this policy violates the Fair Housing Act (FHA) and the Ohio Civil Rights Act (OCRA).The United States District Court for the Northern District of Ohio granted the plaintiffs' motion for class certification, creating the "Water Lien Class" under Rules 23(b)(2) and 23(b)(3) of the Federal Rules of Civil Procedure. The class includes all Black homeowners or residents in Cuyahoga County who have had a water lien placed on their property by Cleveland Water within the last two years. The district court found that the plaintiffs satisfied the requirements of Rule 23(a) and that common questions of law and fact predominated over individual issues.The United States Court of Appeals for the Sixth Circuit reviewed the district court's certification order. The appellate court affirmed the district court's decision, holding that the plaintiffs had standing to pursue their FHA claim on a disparate-impact theory. The court found that the common question of whether Cleveland's water lien policy disproportionately affects Black homeowners predominated over individual issues, satisfying Rule 23(b)(3). The court also held that the district court did not abuse its discretion in certifying the class under Rule 23(b)(2) for injunctive and declaratory relief. The appellate court declined to address the merits of the plaintiffs' FHA claim, focusing solely on the class certification issues. View "Pickett v. City of Cleveland" on Justia Law

Jessica Hines, a dancer, sued National Entertainment Group, LLC (NEG), an adult entertainment club, for failing to properly compensate its employees under various federal and state laws, including the Fair Labor Standards Act and Ohio wage laws. Hines had signed three separate Lease Agreement Waivers with NEG, each containing an arbitration provision. NEG moved to dismiss the suit or stay the proceedings pending arbitration, arguing that Hines had agreed to arbitrate any disputes.The United States District Court for the Southern District of Ohio denied NEG’s motion to dismiss, finding that Hines had plausibly alleged sufficient facts to support standing. The court also denied NEG’s motion to stay the proceedings pending arbitration, concluding that the arbitration provision was both procedurally and substantively unconscionable, and thus unenforceable.The United States Court of Appeals for the Sixth Circuit reviewed the case and vacated the district court’s denial of NEG’s motion to stay. The appellate court held that the arbitration provision was neither procedurally nor substantively unconscionable. The court found that Hines had reasonable opportunity to understand the plain terms of the arbitration clause, which were not hidden in fine print. The court also determined that the arbitration agreement was supported by adequate consideration and that any inconvenience or potential inconsistency caused by separate actions was not a legitimate basis for overriding the arbitration agreement.The Sixth Circuit remanded the case for the district court to consider the remaining factors under Stout v. J.D. Byrider, which include whether the claims fall within the scope of the arbitration agreement, whether Congress intended the federal claims to be arbitrable, and whether to stay the case pending arbitration if some but not all claims are subject to arbitration. View "Hines v. National Entertainment Group" on Justia Law

Plaintiffs, Carvin Thomas and Terrell Lawrence, filed a class-action lawsuit against members of the Tennessee Board of Parole, alleging that the use of a computer test, STRONG-R, to determine parole eligibility violated their constitutional right to due process. They claimed that the test produced inaccurate results due to inadequate training of correctional employees and that the results were kept secret, preventing inmates from challenging them effectively. Both plaintiffs experienced changes in their STRONG-R scores without any new negative behavior, leading to parole denials based on these scores.The United States District Court for the Middle District of Tennessee dismissed the complaint, concluding that the plaintiffs failed to state a plausible claim for relief. The court found that Tennessee’s parole statutes do not confer a protected liberty interest in parole, as they do not create a legitimate expectation of parole.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 Tennessee’s parole statutes do not sufficiently constrain the Board’s discretion to deny parole, thus not creating a constitutionally recognized entitlement to parole. The court noted that while the plaintiffs identified serious issues with the STRONG-R test, the lack of a protected liberty interest in parole precluded their due process claims. Consequently, the court affirmed the dismissal of the plaintiffs' complaint. View "Thomas v. Montgomery" on Justia Law