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

Chance York was found in possession of 99 images and 63 videos of child pornography in Northeastern Ohio in 2024. He pleaded guilty to charges of possessing, receiving, and distributing visual depictions of real minors engaged in sexually explicit conduct. The number of images and videos in his possession influenced the sentencing process, as federal guidelines call for increased penalties when the quantity surpasses certain thresholds.In the United States District Court for the Northern District of Ohio, the sentencing judge applied a five-level enhancement under the federal sentencing guidelines. This was done by treating each of York’s 63 videos as the equivalent of 75 images, according to commentary in the guidelines, resulting in a total of 4,824 images and a recommended guidelines range of 151 to 188 months. The government requested a sentence within the guidelines, while York argued for the statutory minimum of 60 months. The court ultimately imposed a sentence of 120 months, below the guideline range, considering both aggravating and mitigating factors, including the seriousness of the offense and York’s lack of criminal history.The United States Court of Appeals for the Sixth Circuit reviewed the case. York challenged his sentence on both procedural and substantive grounds, arguing that the district court erred in its calculation of the image equivalency and in weighing the sentencing factors. The Sixth Circuit held that the district court properly applied the five-level enhancement using the “75:1 Rule” for videos, as established by binding Sixth Circuit precedent. The appellate court also found no procedural or substantive error in the sentencing judge’s consideration of the statutory factors or in comparison to similar cases. The Sixth Circuit affirmed the district court’s judgment. View "United States v. York" on Justia Law

Steve Croom, Jr. was originally convicted in federal court of conspiracy to launder money and commit wire fraud. Due to his history of alcohol abuse and driving under the influence, the court imposed supervised release conditions prohibiting alcohol use or possession. During his supervised release, Croom violated these conditions three times: first, he was caught drinking and driving and resisted arrest; second, he tested positive for alcohol, but the supervising officer recommended leniency and the court took no action; third, he drove drunk, crashed into another vehicle injuring a mother and her two children, and was convicted in state court for operating a vehicle while impaired and failing to yield.Following these violations, the United States District Court for the Northern District of Ohio held a hearing where Croom admitted to three supervised release violations. The court calculated an advisory sentencing guideline range of 8 to 14 months but imposed a 24-month sentence, varying upward due to the seriousness of Croom’s repeated breaches and the danger posed to the public. The court required alcohol treatment as part of his post-incarceration supervised release.The United States Court of Appeals for the Sixth Circuit reviewed Croom’s appeal, where he challenged the sentence as procedurally and substantively unreasonable. Applying plain error review to his procedural objections, the Sixth Circuit found no error: the district court properly calculated the guidelines, treated them as advisory, considered relevant sentencing factors, relied on appropriate evidence, and adequately explained its reasons. Substantively, the Sixth Circuit held that the district court acted within its discretion in imposing an upward variance, given Croom’s recidivism and failure to change behavior. The court affirmed the district court’s judgment, holding that the 24-month sentence was reasonable and properly explained under federal law. View "United States v. Croom" on Justia Law

A 59-year-old Navy employee began communicating with a 15-year-old boy, M.V., on an online dating site where M.V. falsely listed his age as 18, the minimum allowed by the site. Over several months in 2023, the two exchanged messages, met in person multiple times, and, according to M.V., engaged in sexual acts. The minor’s parents eventually discovered the relationship, notified law enforcement, and participated in a sting operation that resulted in the adult’s arrest. Police recovered evidence from the defendant’s belongings, including items suggesting sexual intent.A grand jury in the United States District Court for the Western District of Michigan indicted the defendant on one count of coercion and enticement of a minor under 18 U.S.C. § 2422(b), and two counts of interstate travel with intent to engage in illicit sexual conduct under 18 U.S.C. § 2423(b). Before trial, the district court excluded sexually explicit portions of the minor’s dating profile under Federal Rule of Evidence 412 and denied a proposed affirmative defense related to reasonable belief of the victim’s age for Counts 2 and 3. The jury convicted the defendant on all counts, and he was sentenced to 156 months in prison.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the conviction on Count 1, holding that the district court’s jury instructions accurately reflected the law and that sufficient evidence supported the conviction. The court found no abuse of discretion in excluding evidence under Rule 412. However, regarding Counts 2 and 3, the court held that the government must prove the defendant intended to engage in a sexual act with a person under 16, not merely under 18, when § 2243(a) is the predicate offense. The convictions on Counts 2 and 3 were vacated and remanded for a new trial with proper jury instructions. View "United States v. Stafford" on Justia Law

The plaintiff, an incarcerated individual at Earnest C. Brooks Correctional Facility in Michigan, sought to challenge the withholding of a book authored by his sister from his mail. The book, which addressed childhood sexual assault, was rejected by a mailroom clerk on the grounds that it allegedly encouraged or provided instruction in criminal activity. After receiving notice of the rejection, the plaintiff requested an administrative hearing. There was a dispute between the parties regarding the timing and number of hearings, but ultimately, the plaintiff claimed he did not receive the hearing report detailing the final decision until May 9, 2022. He then filed a grievance that same day, alleging unjust censorship and procedural due process violations.The Michigan Department of Corrections (MDOC) maintains a multi-step grievance process for prisoner complaints, and under the Prison Litigation Reform Act (PLRA), prisoners must exhaust these remedies before filing suit. The plaintiff’s grievances were denied at each step by MDOC as untimely, based on the department’s interpretation that the grievance should have been filed within five business days of the April 5, 2022, hearing. After exhausting the MDOC process, the plaintiff filed suit in the United States District Court for the Western District of Michigan. The district court granted summary judgment to the defendant, concluding that the plaintiff had not properly exhausted his administrative remedies due to untimeliness.The United States Court of Appeals for the Sixth Circuit reviewed the case and applied de novo review. The court held that the defendant, as the party asserting the affirmative defense of failure to exhaust, did not meet the burden of proving that no genuine dispute existed regarding when the plaintiff received notice of the final decision. The court found that a genuine dispute of material fact remained about the timing of the plaintiff’s awareness of the unresolved issue. The Sixth Circuit reversed the district court’s grant of summary judgment and remanded for further proceedings. View "Tubbs v. Payton" on Justia Law

A Michigan marijuana grower entered into a contract with two subsidiaries of a larger company to supply all marijuana grown in its 2020 and 2021 harvests. At the time of contracting, the grower was licensed by Michigan to produce medical marijuana, while the buyers held both medical and recreational licenses. The contract required the marijuana to meet recreational testing standards, and the buyers paid a deposit. After the initial shipment, the buyers refused further deliveries due to a price drop, prompting the grower to sell the remaining harvests to other entities at lower prices.The grower sued the buyers for breach of contract in Michigan state court, seeking lost profits. The buyers removed the case to the United States District Court for the Eastern District of Michigan, raised counterclaims, and asserted that the contract was unenforceable due to federal illegality. After cross-motions for summary judgment, the district court denied the buyers’ illegality defense and allowed the case to proceed to trial. A jury found the buyers liable and awarded substantial damages to the grower. The buyers renewed their motion for judgment as a matter of law and requested a new trial, again arguing federal illegality.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial de novo. The Sixth Circuit held that federal courts cannot enforce contracts founded on agreements to commit conduct that is explicitly prohibited by federal law, such as distribution and possession of marijuana under the Controlled Substances Act. Because the contract was not limited to medical use and encompassed conduct criminalized under federal law, the court found the contract unenforceable. The Sixth Circuit reversed the district court’s denial of the buyers’ motion for judgment as a matter of law. View "Hello Farms Licensing MI, LLC v. GR Vending MI, LLC" on Justia Law

Kevin Lackey was convicted in 1993 by a Michigan jury of criminal sexual conduct and breaking and entering after he was accused of sexually assaulting an eleven-year-old girl in her home. The incident involved an assailant who allegedly entered through a window, abducted the victim from her bedroom, and assaulted her on the back porch before fleeing. Police quickly responded, gathered statements, and relied on a police dog that tracked from the crime scene to Lackey’s nearby residence. Lackey matched the physical description given by the victim and her mother. After serving 22 years in prison, his convictions were vacated due to significant issues with the dog-tracking evidence, and the prosecutor chose not to retry the case.Following the vacatur of his convictions, Lackey filed a lawsuit under 42 U.S.C. § 1983 in the United States District Court for the Eastern District of Michigan. He alleged that several investigating officers fabricated evidence, maliciously prosecuted him, and suppressed exculpatory material, thereby violating his constitutional rights. The district court granted summary judgment in favor of the officers, finding them entitled to qualified immunity, and Lackey settled his remaining claims against another defendant before final judgment was entered.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court affirmed the district court’s judgment, holding that Lackey failed to show the officers violated clearly established constitutional rights. The court found no genuine dispute as to material fact that would defeat qualified immunity on claims of fabrication of evidence, malicious prosecution, or suppression of exculpatory evidence. Specifically, the court concluded there was probable cause supporting Lackey’s arrest and prosecution, and no evidence that the officers withheld material information or fabricated evidence in a way that affected the outcome of the trial. The judgment in favor of the officers was therefore affirmed. View "Lackey v. Hurley" on Justia Law

A seven-year-old child named J.T. died after being physically restrained by care workers at a behavioral care center in Kentucky. The restraint, described as a “kneeling cradle,” was performed by employees of the center’s management company, Seven Counties Services, Inc. Following J.T.’s death, his estate filed a wrongful death lawsuit against the care center, Seven Counties, and other parties. Seven Counties sought defense and indemnity from its insurers, Mental Health Risk Retention Group (MHRRG) and Scottsdale Insurance Company, under its insurance policies, but both insurers denied coverage, citing exclusions for “professional services.”After the underlying wrongful death suit was filed, Hanover Insurance Group, which insured Uspiritus (the center’s operator), agreed to defend Uspiritus but declined coverage for Seven Counties, arguing that Seven Counties was not named as an additional insured after a written agreement expired. MHRRG and Scottsdale continued to deny coverage for Seven Counties, asserting that the restraint was a professional service excluded from coverage. The insurers then filed a declaratory judgment action in the United States District Court for the Western District of Kentucky. The district court granted summary judgment for Seven Counties as to the duty to defend but granted summary judgment for the insurers as to the duty to indemnify, finding the restraint was a professional service and thus excluded from indemnification.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The Sixth Circuit affirmed the district court’s ruling, holding that the act of restraining J.T. constituted a professional service under Kentucky law, given the specialized training, required judgment, and regulatory oversight involved. Thus, the professional services exclusion in the insurance policy applied, and the insurers had no duty to indemnify Seven Counties for liability arising from the underlying wrongful death action. View "Scottsdale Ins. Co. v. Seven Cntys. Servs., Inc." on Justia Law

A Kentucky resident developed malignant mesothelioma, which is linked to asbestos exposure. He had worked for over a decade as a millwright at General Electric’s Appliance Park in Louisville and had also been exposed to asbestos dust from his father’s clothes as a child. After his diagnosis, he and his wife filed suit in Kentucky state court against General Electric and other defendants, alleging injuries from asbestos exposure that occurred during his civilian employment.During discovery, General Electric learned that the decedent had served in the U.S. Navy and had filed a Veterans Affairs claim for asbestos-related injuries from his military service. GE asserted that it could raise a federal-contractor defense related to its provision of turbines to the Navy and removed the case to federal court under 28 U.S.C. § 1442. In response, the plaintiffs submitted an affidavit and later an amended complaint, explicitly disclaiming any claims arising from military service or exposure to asbestos during that time. The plaintiffs then moved to remand the case back to state court.The United States District Court for the Western District of Kentucky granted the motion to remand, finding GE could not assert a colorable federal defense given the amended complaint’s explicit disclaimers. The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The Sixth Circuit held that, following Supreme Court precedent, federal jurisdiction must be determined based on the operative complaint. Since the amended complaint disclaimed all claims related to federal conduct, GE no longer had a colorable federal defense, and the federal court lacked jurisdiction under § 1442. Thus, remand to state court was proper. View "Horton v. General Electric" on Justia Law

A company engaged in outdoor advertising sought to erect a large billboard in a business district of Bath Township, Ohio. The local zoning inspector denied its application, citing a categorical ban on “off-premises” signs under the township’s zoning resolution. The company’s proposed billboard would have been a two-sided structure, 30 feet tall and 360 square feet per side. Notably, the company did not challenge other relevant provisions of the zoning resolution, such as the bans on “pole signs” and “high-rise” signs, which also would have prohibited the proposed billboard.The company, joined by a related entity, filed suit in the United States District Court for the Northern District of Ohio, asserting that the off-premises sign ban violated the First Amendment and conflicted with Ohio law. The defendants, Bath Township’s board of trustees and zoning officials, moved to dismiss on the ground that the plaintiffs lacked standing because even if the off-premises ban were invalidated, other unchallenged provisions would still bar the billboard. The district court agreed and dismissed the case, declining to exercise supplemental jurisdiction over the state law claim.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The court held that the plaintiffs lacked Article III standing because invalidating the off-premises sign ban would not redress their injury, as the bans on pole and high-rise signs would independently prohibit the billboard. The court found that this reasoning was controlled by its prior decision in Midwest Media Property, L.L.C. v. Symmes Township. The Sixth Circuit also found that the plaintiffs had forfeited any alternative standing theories, such as those based on the permitting process or application fees, by not properly raising them. The judgment of the district court was affirmed. View "Summit Locations, LLC v. Bd. of Trustees, Bath Township" on Justia Law

Israel Bo Sword worked as a heavy equipment operator for VNS Federal Services, LLC at the Portsmouth Gaseous Diffusion Plant in Ohio, where he and co-workers were represented by the International Union of Operating Engineers, Local 18. VNS was bound by the General Presidents’ Project Maintenance Agreement (GPPMA) in its dealings with the Union. In February 2020, Sword complained to his supervisor that a side agreement guaranteeing another operator 40 hours per week violated the collective bargaining agreement, and he later sought assistance from his union representative to address his concerns. Shortly after the union meeting with management about Sword’s complaint, Sword was permanently laid off, while other operators returned to work.Sword filed unfair labor practice charges against VNS with the National Labor Relations Board (NLRB), alleging unlawful discharge in retaliation for engaging in protected concerted activity. After a hearing, an administrative law judge found that VNS violated Sections 8(a)(3) and (1) of the National Labor Relations Act (NLRA). VNS filed exceptions, but the NLRB affirmed the ALJ’s findings and issued an order requiring VNS to offer Sword reinstatement, provide backpay, and post remedial notices. The NLRB declined to resolve disputes over remedies at that stage, following its practice of deferring such issues to compliance proceedings.The United States Court of Appeals for the Sixth Circuit reviewed the NLRB’s petition to enforce its order. The court found substantial evidence supporting the NLRB’s determination that Sword engaged in protected concerted activity, that VNS discharged him because of animus toward that activity, and that VNS’s justification for the layoff was pretextual. The Sixth Circuit granted enforcement of the NLRB’s order in full, declining to address challenges to the scope of remedies until compliance proceedings are completed. View "NLRB v. VNS Fed. Servs., LLC" on Justia Law