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

A quadriplegic individual applied to become a foster parent in Michigan, relying on a network of full-time aides and informal caregivers to assist with physical tasks. Despite successfully completing initial steps of the application process, her physician’s medical statement indicated she was physically incapable of caring for a foster child. The private agency overseeing her application, after home visits and a review of her situation, recommended against granting her a foster license, citing several state regulatory provisions related to the physical and mental health required of foster parents. The state agency subsequently administratively closed her application, permitting her to reapply at any time or provide additional information.The United States District Court for the Eastern District of Michigan reviewed the case after the applicant sued the State of Michigan, individual officials, and the private agency, alleging violations of the Americans with Disabilities Act (ADA), the Rehabilitation Act, and the Equal Protection Clause. The parties filed cross-motions for summary judgment. The district court granted summary judgment in favor of the defendants on all claims, finding that the applicant’s proposed accommodation—her network of aides—was not a reasonable accommodation under the ADA or Rehabilitation Act, and that the defendants’ actions were rationally related to legitimate state interests.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s grant of summary judgment. The court held that while the ADA and Rehabilitation Act require individualized assessments and reasonable accommodations, the applicant’s patchwork of formal and informal assistance did not reliably assure the physical care of foster children, making her accommodation request unreasonable. The court also found no facial disability discrimination in Michigan’s foster care regulations and concluded that the defendants’ actions did not violate Equal Protection, as they were rationally related to ensuring child safety. View "Metcalf v. Michigan" on Justia Law

A tenured law professor at a state university posted an online petition calling for military action against Israel. The university responded by placing the professor on administrative leave and restricting his campus access while it investigated whether his actions violated university policy or law. The investigation included notices to the professor, requests for evidence, and allegations from students, but had not progressed beyond the preliminary fact-finding stage. No formal hearing or charges had been initiated by the university at the time of the lawsuit.The professor filed suit in the United States District Court for the Eastern District of Kentucky, seeking a preliminary injunction to stop the university’s actions. The university moved for abstention under the doctrine established in *Younger v. Harris*, arguing that the ongoing university investigation constituted a state proceeding warranting federal court abstention. The district court agreed with the university and abstained from hearing the case, prompting the professor to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s abstention decision de novo. The Sixth Circuit held that the university’s investigation was still in a preliminary, investigatory stage and did not constitute an ongoing formal proceeding as required under the *Younger* abstention framework. The court distinguished the circumstances from prior cases involving formal disciplinary hearings, noting that no formal charges or hearings had yet been initiated. As a result, the Sixth Circuit reversed the district court’s decision to abstain and remanded the case for consideration of the professor’s motion for a preliminary injunction. View "Woodcock v. Univ. of Kentucky" on Justia Law

A large public pension fund alleged that a government-sponsored enterprise and three of its senior officers made false and misleading statements regarding the company’s exposure to subprime and Alt-A mortgages during a period preceding the 2008 financial crisis. The pension fund claimed that the company’s public statements and disclosures understated its exposure to high-risk loans, while internal documents and risk assessments suggested a much greater level of risk. It further argued that, when the company’s actual exposure came to light, its stock price fell, resulting in significant losses to shareholders.Previously, the United States District Court for the Northern District of Ohio denied class certification, excluded the pension fund’s expert, and granted summary judgment to the defendants. The court concluded that the pension fund failed to establish reliance due to an inability to show that the company’s stock traded in an efficient market, improperly rejected the fund’s price-maintenance theory of fraud, found insufficient evidence to support loss causation and damages, and determined the defendants did not act with scienter. The court also found no actionable misstatements regarding credit-risk and underwriting standards, and dismissed control-person liability claims after finding no underlying securities violation.On appeal, the United States Court of Appeals for the Sixth Circuit reversed in part, vacated in part, and remanded. The appellate court held that the pension fund presented sufficient evidence for a jury to find that the company made materially false or misleading statements regarding its subprime and Alt-A exposure, and that issues of scienter and reliance were present. The court determined that the lower court erred in rejecting the price-maintenance theory and improperly excluded the plaintiff’s expert. It also concluded that the fund should be allowed another opportunity to seek class certification and to present evidence of loss causation and damages. The court reinstated the underlying securities fraud and control-person liability claims for further proceedings. View "OPERS v. FHLMC" on Justia Law

A 15-year-old, ELG, participated in a vocational program for teenagers that included a visit to a Michigan district court. During a lecture given by Judge Kenneth J. King about his career, ELG fell asleep, which offended Judge King. In response, Judge King orchestrated a plan to “scare her straight” by having ELG handcuffed, placed in a detention cell, required to wear a prison jumpsuit, and later subjected her to a mock trial in front of her peers, which was streamed online. There was no official court proceeding, case number, or record associated with these actions, and Judge King later admitted his actions were intended to teach ELG a lesson for perceived disrespect.Following these events, Latoreya Till, ELG’s mother, filed a lawsuit in the United States District Court for the Eastern District of Michigan. The complaint alleged violations of ELG’s Fourth Amendment rights and state law torts. Judge King moved to dismiss the case, arguing judicial immunity protected him from suit. The district court denied his motion, finding that the conduct alleged was not within the scope of judicial functions. Judge King appealed, and Till cross-appealed on an alternative theory.The United States Court of Appeals for the Sixth Circuit reviewed the lower court’s denial of the motion to dismiss de novo. It held that Judge King’s alleged actions were not judicial acts because they did not constitute functions normally performed by a judge nor did they occur in his judicial capacity. The court further found that Till’s alternative argument, based on a “complete absence of all jurisdiction,” was inapplicable. The Sixth Circuit affirmed the district court’s decision, holding that Judge King was not entitled to judicial immunity at this stage of the proceedings. View "Till v. King" on Justia Law

In this case, two individuals served as members of the Human Relations Commission (HRC) in Hamtramck, Michigan, which oversaw city-owned flagpoles along a main avenue. For a decade, the HRC operated under an unwritten policy that allowed residents to request flags to be flown, including flags of different nations and various groups, such as the Pride flag. After a change in city administration in 2021, tension arose when the HRC flew the Pride flag in 2022. Responding to controversy, the newly elected City Council enacted a resolution in 2023 restricting the flagpoles to only certain flags—specifically, the American, Michigan, Hamtramck, and Prisoner of War flags, as well as those of nations representing the city’s international character. When the plaintiffs raised the Pride flag in defiance, the City Council removed them from the HRC and stripped the HRC’s authority over the flagpoles.The plaintiffs then brought suit in the United States District Court for the Eastern District of Michigan, alleging violations of the Free Speech, Establishment, and Equal Protection Clauses. The district court granted summary judgment in favor of the City and its officials, finding that after the 2023 resolution, the flagpoles served as a forum for government speech, not private speech, and that the resolution was facially neutral regarding religion and not motivated by religious purpose. The court also determined that the plaintiffs had not adequately developed an equal protection claim.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the City permissibly closed the flagpoles to private speech, making them a vehicle solely for government speech, and thus the plaintiffs’ Free Speech Clause claim failed. The court also held that the plaintiffs’ Establishment Clause claim was unavailing, as there was no evidence the resolution’s primary purpose was to advance religion. Finally, the court concluded the plaintiffs had forfeited their equal protection claim by not developing it. View "Gordon v. City of Hamtramck, Mich." on Justia Law

A company sponsored a health benefit plan for its employees, which was administered by another entity. An employee under this plan, referred to as Patient AA, sought medical treatment from several out-of-network providers. Before providing care, these providers contacted the plan administrator to confirm the reimbursement rate. The administrator’s employees orally stated that reimbursement would be at the usual, customary, and reasonable (UCR) rate, a standard commonly used in the industry. Relying on these assurances, the providers treated Patient AA. When they later sought payment, they were reimbursed at a much lower rate, calculated according to Medicare rates, not the promised UCR rate.The providers sued both the employer and the plan administrator, asserting state-law claims for negligent misrepresentation and promissory estoppel based on the oral statements about reimbursement. The action began in California state court but was removed to federal court and transferred to the United States District Court for the Eastern District of Michigan. The defendants moved to dismiss the complaint, arguing that the claims were preempted by the Employee Retirement Income Security Act of 1974 (ERISA). The district court agreed, applying the Sixth Circuit’s decision in Cromwell v. Equicor-Equitable HCA Corp., and dismissed the complaint with prejudice, finding that the claims “related to” the ERISA plan and were thus preempted. The district court also denied the providers’ post-judgment request for leave to amend their complaint.The United States Court of Appeals for the Sixth Circuit affirmed. The court held that, under its precedent in Cromwell, ERISA expressly preempts state-law negligent-misrepresentation and promissory-estoppel claims by third-party healthcare providers when those claims are based on oral assurances regarding the terms of coverage or reimbursement under an ERISA-governed plan. The district court’s dismissal with prejudice was upheld. View "Laurel Hill Mgmt. Servs., Inc v. La-Z-Boy Inc." on Justia Law

Steven Neal was charged with attempting to entice a 12-year-old girl to engage in illegal sexual activity over a nearly two-year period, during which he also sexually assaulted the victim on two occasions. Neal communicated with the girl through Facebook Messenger and, during the charged period, committed the assaults—one in July 2022 at a cabin and another in August 2023 at his home. Neal pleaded guilty to the enticement charge and admitted to the assaults during his plea.In the United States District Court for the Eastern District of Kentucky, Neal’s presentence report recommended several sentencing enhancements based on the two sexual assaults. Neal objected, arguing that only his messaging, not the assaults, should be considered for sentencing. The district court overruled his objections, finding the assaults to be “relevant conduct” under U.S.S.G. § 1B1.3, applying cross-references and enhancements to arrive at a guidelines range of 292 to 365 months. Neal was sentenced to 292 months’ imprisonment.On appeal to the United States Court of Appeals for the Sixth Circuit, Neal challenged both the procedural and substantive reasonableness of his sentence. The Sixth Circuit found that the district court correctly considered the assaults as relevant conduct since they occurred during the commission of the continuing enticement offense, had a logical relationship to it, and were independently criminal. The court also found no error in applying the sentencing enhancements and rejected arguments that their application resulted in impermissible double counting. The appellate court further determined that the sentence, imposed at the bottom of the guidelines range, was substantively reasonable given the seriousness of the offense and the district court’s consideration of mitigating factors. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Neal" on Justia Law

While on parole for prior state drug offenses, Frank Clay, Jr. was involved in a late-night disturbance at a convenience store in Grand Rapids, Michigan, in July 2024. Witnesses reported that Clay was carrying a firearm and acting aggressively. When law enforcement arrived, Clay resisted arrest and, during the struggle, bit an officer on the groin, causing an injury that required medical attention. Upon searching Clay, officers found a pistol, approximately 16 grams of cocaine divided into 11 baggies, and $230 in cash. Later investigation revealed that the pistol was reported as stolen and that Clay was on parole for multiple drug convictions.Clay was charged in the United States District Court for the Western District of Michigan with possessing a firearm as a felon and pleaded guilty without a plea agreement. At sentencing, the Probation Office recommended three sentencing enhancements: reckless endangerment (for biting the officer), possession of a firearm in connection with another felony (possessing cocaine with intent to distribute), and possession of a stolen firearm. Clay objected to each enhancement and also requested that his federal sentence run concurrently with any potential state sentence for parole violation. The district court overruled his objections, applied all three enhancements, and imposed a sentence of 151 months to run consecutive to any state sentence.On appeal to the United States Court of Appeals for the Sixth Circuit, Clay challenged the application of the three sentencing enhancements and the imposition of a consecutive sentence. The Sixth Circuit held that the district court did not err in applying the enhancements: the evidence supported findings of reckless endangerment, intent to distribute cocaine, and possession of a stolen firearm. The court also found no error in the imposition of a consecutive sentence, noting that the district court’s reasoning was sufficient. The judgment of the district court was affirmed. View "United States v. Clay" on Justia Law

Roy Christopher West was convicted in 2007 of using interstate facilities to commission a murder-for-hire, after Leonard Day, who had stolen from West, was killed in Detroit. Evidence showed West offered money for Day’s murder and coordinated with two accomplices, supplying them with weapons and vests. After Day was shot, cell phone data placed one accomplice at the scene, and subsequent calls and conversations implied West’s involvement and satisfaction with the outcome. West was charged under 18 U.S.C. § 1958, which carries a ten-year maximum unless “death results,” in which case a mandatory life sentence applies. However, the indictment did not specifically charge the “death results” enhancement, nor was the jury instructed on it.Following his conviction, West’s direct appeal to the United States Court of Appeals for the Sixth Circuit raised various evidentiary issues but not the Apprendi error concerning the sentencing enhancement. The Sixth Circuit affirmed his conviction. West’s initial motion under 28 U.S.C. § 2255 also did not include the Apprendi claim. His conviction became final in 2013, and he filed his § 2255 motion just before the one-year deadline. Years later, he raised the Apprendi issue for the first time in a Rule 60(b)(6) motion after unsuccessful attempts at compassionate release and other post-conviction relief. The United States District Court for the Eastern District of Michigan denied the Rule 60(b) motion, holding that any renewed § 2255 claim would be time-barred and that West did not qualify for equitable tolling or other exceptions.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial, holding that Rule 60(b)(6) relief was unavailable because any underlying Apprendi-based claim would be barred by § 2255’s one-year statute of limitations and West failed to demonstrate grounds for tolling or an actual innocence exception. The court ruled that procedural barriers and lack of diligence prevented reopening the judgment. View "West v. United States" on Justia Law

Tianna Barber was implicated in a major drug trafficking operation in Toledo, Ohio, which sourced heroin, fentanyl, cocaine, and methamphetamine from a Mexican cartel. Federal investigators, after surveilling a courier and Derrick Murphy, uncovered Barber’s involvement as Murphy’s intermediary while he was incarcerated. She facilitated drug transactions, stored drugs at her home, transported proceeds, purchased a firearm for Murphy, and personally sold drugs. Based on these activities, Barber was indicted on conspiracy, distribution, possession with intent to distribute, and facilitating drug felonies by telephone.A jury in the United States District Court for the Northern District of Ohio found Barber guilty of conspiracy, distribution, and possession counts, and one count of using a telephone to further a drug felony, but acquitted her on a second telephone facilitation count. The jury specified that she conspired to distribute less than the charged amounts for each drug. At sentencing, the Probation Office attributed higher drug quantities to Barber based on trial testimony, leading to objections from her regarding witness credibility and the appropriateness of considering drug quantities not found by the jury. The district court overruled her objections, adopted the Probation Office’s findings, and imposed a sentence below the advisory guidelines range.The United States Court of Appeals for the Sixth Circuit reviewed Barber’s appeal. She challenged evidentiary rulings, arguing improper expert interpretation of jail calls and a Confrontation Clause violation regarding a video of a controlled buy, and contested her sentence as relying on acquitted conduct. The Sixth Circuit held the evidentiary rulings were not erroneous under the applicable standards of review, found no Confrontation Clause violation as the challenged statements were not hearsay, and concluded the district court did not plainly err in its sentencing calculation, as the conduct considered overlapped with her convictions. The court affirmed the judgment. View "United States v. Barber" on Justia Law