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

Walker was involved in a scheme with two others to distribute cocaine. He arranged for cocaine to be mailed from a supplier near the U.S.-Mexico border, using one co-conspirator to send the packages and a postal worker whom he paid to deliver them along his mail routes. Law enforcement intercepted two cocaine packages, observed Walker conducting drug sales from his girlfriend’s home, and later searched that residence, finding drugs, paraphernalia, and Walker’s phone. Walker confessed to drug activities after the search.The United States District Court for the Western District of Michigan denied Walker’s motion to suppress evidence from the residence, finding probable cause for the search warrant and, alternatively, that the good-faith exception applied. At trial, the jury convicted Walker on all counts related to the drug conspiracy, and he was sentenced to 360 months’ imprisonment.Walker appealed to the United States Court of Appeals for the Sixth Circuit, raising three main issues. First, he argued that the evidence from the search should have been suppressed. The Sixth Circuit found the warrant affidavit was sufficient to establish probable cause and, even if not, that the officers' reliance on the warrant was objectively reasonable under the good-faith exception. Second, Walker challenged the admission of statements he made during a proffer session, asserting protection under Federal Rule of Evidence 410. The appellate court held that Walker, through counsel, had waived this argument by conceding that certain statements were admissible due to their inconsistency with his trial defense. Third, Walker argued a violation of his Confrontation Clause rights regarding a co-defendant’s testimony. The court found this right was also waived when Walker and his counsel agreed to a curative instruction for the jury to disregard the testimony. The Sixth Circuit affirmed the convictions. View "United States v. Walker" on Justia Law

A financial services company operating a designated contract market began offering sports-event contracts, which allowed users to buy and sell positions based on the outcome of various sporting events. These offerings attracted the attention of Ohio and Tennessee state gambling regulators, who asserted that the company was violating state gambling laws by operating without appropriate licenses and by allowing underage users to participate. Both states sent cease-and-desist letters to the company, demanding it stop offering sports-event contracts to their residents. The company, which claimed to be federally authorized under the Commodity Exchange Act (CEA), argued that federal law preempted state regulation of its activities.In Ohio, the company filed suit in the United States District Court for the Southern District of Ohio, seeking a preliminary injunction to prevent enforcement of state gambling laws against it. The district court denied the injunction, finding the company had not demonstrated that its sports-event contracts were “swaps” subject to exclusive jurisdiction of the Commodity Futures Trading Commission (CFTC) and, even if they were, had not established federal preemption. The company appealed. In Tennessee, a similar suit was filed in the United States District Court for the Middle District of Tennessee, which granted a preliminary injunction, holding the company was likely to succeed because the contracts constituted “swaps” and conflict preemption applied. Tennessee officials appealed.The United States Court of Appeals for the Sixth Circuit reviewed both cases together. It held that the company’s sports-event contracts did not satisfy the statutory definition of a “swap” under the CEA and thus did not fall within CFTC exclusive jurisdiction. The court further held that, even assuming the contracts were swaps, the CEA neither expressly nor impliedly preempted Ohio’s or Tennessee’s gambling laws. The Sixth Circuit affirmed the denial of the preliminary injunction in Ohio, vacated the grant of the injunction in Tennessee, and remanded for further proceedings. View "KalshiEX LLC v. Schuler" on Justia Law

After the Supreme Court’s Dobbs decision, Tennessee enacted a near-total abortion ban and later passed the Underage Abortion Trafficking Act, which included the “Recruitment Provision.” This provision criminalizes intentionally recruiting an unemancipated minor for an abortion that would be illegal in Tennessee, even if the procedure is legal where performed. Two advocates for abortion rights, Welty and Behn, regularly provide counseling and information to minors about obtaining legal abortions, including out-of-state options. Concerned that the new law would criminalize their advocacy and speech, they filed a pre-enforcement suit against several district attorneys general, alleging First Amendment violations.The case was first reviewed by the United States District Court for the Middle District of Tennessee. After a preliminary injunction hearing and cross-motions for summary judgment, the district court granted summary judgment in favor of Welty and Behn, holding that the Recruitment Provision is both unconstitutional as applied and facially overbroad under the First Amendment. The district court issued an injunction preventing enforcement of the Recruitment Provision by the defendants, but rejected the plaintiffs’ claim that the law was unconstitutionally vague.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s rulings de novo. The Sixth Circuit affirmed the lower court’s holding, concluding that the Recruitment Provision constitutes unconstitutional viewpoint discrimination and is substantially overbroad, thus facially violating the First Amendment. The court determined that the statute impermissibly restricts protected speech regarding legal abortions and cannot survive strict scrutiny. The court also affirmed the scope of the district court’s injunction, which barred enforcement of the Recruitment Provision. View "Welty v. Dunaway" on Justia Law

A testamentary trust was created by Ruth Wilson for her daughter, Elizabeth Koeberer, before Wilson’s death in 2013. The trust, named with a misspelling of Koeberer’s surname, was initially managed by Koeberer’s brother, Edson Wilson, who later appointed Robert Weir as successor trustee. JPMorgan Chase Bank held the trust’s financial assets. Nearly a decade after Wilson’s death, Koeberer brought a federal lawsuit against Weir, Chase Bank, her siblings, and her former probate attorney, alleging negligence, violations of federal statutes, and abuse-of-process claims in relation to the trust’s administration.The United States District Court for the Southern District of Ohio dismissed all federal claims against the defendants. It found that Koeberer’s claims under the Bank Secrecy Act, the Electronic Fund Transfer Act (EFTA), and the NACHA operating rules were either untimely, lacked a private right of action, or were unsupported by the agreement between Koeberer and Chase Bank. The court also concluded that the economic-loss rule barred Koeberer’s negligence claim against Chase Bank and found no viable abuse-of-process claim against her siblings. The district court declined to exercise supplemental jurisdiction over the remaining state-law claims against Weir and Ryan Gordon, dismissing them as well.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo and affirmed. The appellate court held that there was no private right of action under the Bank Secrecy Act for the SAR filing requirement, Koeberer’s EFTA claim was barred by the one-year statute of limitations, and the NACHA rules were not incorporated into her deposit account agreement. The court also upheld dismissal of the negligence and abuse-of-process claims, and found no abuse of discretion in the district court’s refusal to exercise supplemental jurisdiction over remaining state-law claims. View "Koeberer v. Weir" on Justia Law

The Commonwealth of Kentucky initiated a lawsuit against several pharmacy benefit managers (PBMs) and related entities, asserting that these firms contributed to the opioid crisis in Kentucky by conspiring with drug manufacturers to increase opioid supply. Kentucky alleged the PBMs negotiated with drug companies to give opioids preferred placement on formularies in exchange for rebates and fees, thus violating state consumer protection laws and creating a public nuisance. The PBMs served both federal and commercial clients, including federal workers under the Federal Employees Health Benefits Act, TRICARE members, and Veterans Health Administration beneficiaries.Following removal of the case to the United States District Court for the Eastern District of Kentucky by the PBMs under the federal officer removal statute (28 U.S.C. § 1442), Kentucky sought to remand the case to state court, arguing its complaint disclaimed liability for conduct undertaken at the direction of federal officers. The district court granted Kentucky’s motion to remand.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. Relying on its prior decision in Ohio ex rel. Yost v. Ascent Health Services, LLC, and similar decisions from other circuits, the Sixth Circuit determined the PBMs acted under federal officers when administering federal health benefits and that Kentucky’s claims related to conduct performed under federal supervision. The court found the PBMs had raised colorable federal defenses, including immunity and preemption under federal statutes governing federal health plans, TRICARE, ERISA, and Medicare Part D. The court concluded that Kentucky’s complaint targeted indivisible conduct relating to federal duties, so the PBMs met the requirements for removal under § 1442. The Sixth Circuit reversed the district court’s remand order and remanded the case for further proceedings. View "Commw. of Ky. v. Express Scripts, Inc." on Justia Law

The plaintiff companies, which provide electrical construction and utility services in Kentucky, sued a former vice president and two related defendants after discovering that the former employee had transmitted confidential pricing and rate materials to a competitor, Kent Power, prior to his termination. The plaintiffs alleged that the competitor was seeking to obtain contracts with a major client, Louisville Gas & Electric (LG&E), and argued that the disclosures threatened their business interests. The defendants contended that the disputed LG&E contract involved transmission work which the plaintiff companies could not perform due to lack of equipment, although they were concerned Kent Power might later pursue distribution work, a major part of plaintiffs’ business.The United States District Court for the Western District of Kentucky granted a preliminary injunction. It found that the plaintiffs were likely to succeed on their trade secret claims and would suffer irreparable harm, reasoning that the relationship between Kent Power and LG&E could lead to significant competitive injury. The injunction restrained the defendants from using or disclosing plaintiffs’ confidential information, required forensic examination of the defendants’ devices, and prohibited Kent Power from working on the LG&E contract and from pursuing other business with United Electric customers. The defendants challenged the order’s breadth and the lack of forensic safeguards.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s order for abuse of discretion. It held that the plaintiffs failed to demonstrate irreparable harm because there was no evidence that Kent Power had taken business from the plaintiffs or posed an imminent competitive threat. The court also determined that the forensic provisions of the injunction were overbroad and lacked necessary protections for the defendants’ confidential information. The Sixth Circuit vacated the preliminary injunction and remanded the case for further proceedings. View "UEC Holdings, Inc. v. Hatcher" on Justia Law

The defendant engaged in repeated threatening communications directed at two members of Congress, including violent voicemails and explicit threats to harm and kill them. These actions occurred over a period from 2022 to 2024, escalating in severity, culminating in a particularly violent message in July 2024. The defendant pleaded guilty to transmitting a threat in interstate commerce based on the July 2024 voicemail.The United States District Court for the Eastern District of Tennessee sentenced the defendant to twenty-four months’ imprisonment and one year of supervised release. As a condition of supervised release, the court imposed a broad ban prohibiting any contact with all members of Congress, directly or indirectly, including through third parties and social media, regardless of the nature or purpose of the communication. The district court stated the condition was necessary to protect the public and deter similar conduct. The defendant did not object at sentencing but timely appealed, arguing the condition was overly broad and infringed his First Amendment rights.The United States Court of Appeals for the Sixth Circuit reviewed the supervised release condition for plain error, due to the lack of objection below. The court found that the district court’s condition was overly broad and constituted error, as it imposed a greater deprivation of liberty than was reasonably necessary and burdened constitutional rights, including the right to petition Congress. However, the Sixth Circuit concluded that the error was not obvious or clear under existing law, since there was no binding precedent directly addressing such a broad restriction in this specific context. Therefore, the court affirmed the district court’s decision, holding that while the supervised release condition was erroneous, it did not meet the stringent requirements for plain error reversal. View "United States v. Hayes" on Justia Law

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