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

Federal agents tracked Rivas from Texas to Memphis, suspecting he might be trafficking drugs. Rivas later met defendants and the three drove around Memphis in multiple vehicles before arriving at a warehouse. One of the vehicles was a tractor-trailer. The tractor was registered to Rivas. When agents moved in to investigate, defendants complied, but Rivas fled. While a search for Rivas was ongoing, a narcotics dog alerted the officers to the presence of controlled substances in the trailer. The agents later recovered, among other things, one ton of marijuana under the floor of the trailer. In the prosecution that followed, the district court ruled that defendants were unlawfully detained and, as a remedy, suppressed the marijuana evidence as to them, but not as to Rivas, whom it found was lawfully seized. The Sixth Circuit reversed, stating that the recovered evidence was not the product of defendants’ detention, so, lawful or not, suppression was not warranted. Given the officers’ reasonable suspicion that Rivas was using the tractor-trailer to traffic drugs and their knowledge that Rivas owned the tractor, they had authority to detain the vehicle at least briefly. View "United States v. Figuerdo-Diaz" on Justia Law

In June 2007, Louzon, a Ford product engineer, took an approved leave of absence to visit family in Gaza. While he was there, security issues in the region caused Israel to close its borders, making it impossible for Louzon to return to the U.S. before the end of his leave. Ford initially extended his leave, but by the time the State Department was able to evacuate Louzon in August 2007, the extension had expired. Ford terminated his employment. In 2009, Louzon filed suit, alleging age and national-origin discrimination, moved to exclude Louzon’s evidence of comparable employees on the basis that none were similarly situated as a matter of law. The district court granted Ford’s motion and then granted summary judgment to Ford. The Sixth Circuit reversed on the motion in limine, holding that the district court improperly considered nonevidentiary issues in-limine, and vacated the summary judgment. View "Louzon v. Ford Motor Co." on Justia Law

Suazo is a Honduran immigrant. He entered the U.S. without inspection in 1998. He has been in the U.S. continuously since that time. In 1999, Suazo was granted Temporary Protected Status (TPS) due to his Honduran citizenship. His TPS designation has been continuously renewed due to his continued good moral character, but could potentially be discontinued anytime without notice. In 2010, Suazo married Stacey, who filed an Immediate Relative I-130 Petition on behalf of her husband. Suazo filed an accompanying I-485 Application for Adjustment of Status form, seeking to become a Lawful Permanent Resident (8 U.S.C. 1255). The Suazos had an interview with immigration officials. Stacey’s petition was approved, providing an independent basis to become an LPR. Suazo’s LPR Application, however, was denied because he entered without inspection. The district court dismissed their petition, deferring to the government’s interpretation of the Immigration and Nationality Act, 8 U.S.C. 1101–1537. The Sixth Circuit reversed and remanded, stating that it was “disturbed by the Government’s incessant and injudicious opposition in cases like this, where the only purpose seems to be a general policy of opposition for the sake of opposition.” View "Flores v. U.S. Citizenship & Immigration Servs." on Justia Law

While awaiting a hearing, Zabawa made threats and behaved in an agitated way. Officer Murphy decided to handcuff Zabawa to prevent him from disarming an officer. Before he could do so, Zabawa lunged at Murphy and started punching him. Murphy blocked the attack, and got Zabawa onto the floor by elbowing, kneeing, and headbutting him. After a struggle, Murphy handcuffed Zabawa with the help of other officers. During the fight, Murphy suffered a cut over his eye that required stitches. Murphy testified that he did not know whether the cut happened when he headbutted Zabawa or when Zabawa punched him. A grand jury indicted Zabawa for assaulting and “inflicting bodily injury” on a federal officer, 18 U.S.C. 111(a)(1) and (b). Zabawa’s trial did not take place for more than five and a half years. After Zabawa was found competent to stand trial, the court denied a motion to dismiss based on the delay. Zabawa was convicted and sentenced to 222 months’ imprisonment. The Sixth Circuit reversed, reasoning that “inflict” is a narrower term than “cause” and that Murphy admitted that the injury might have resulted from his application of force to Zabawa, rather than from force Zabawa applied to him. View "United States v. Zabawa" on Justia Law