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

In Michigan, citizens can amend the state constitution through ballot initiatives without legislative approval. Two state senators and nine state representatives challenged the use of such initiatives to regulate federal elections, arguing it violated the U.S. Constitution's Elections Clause. They sought to prevent Michigan officials from enforcing these amendments.The United States District Court for the Western District of Michigan dismissed the case, ruling that the legislators lacked standing to sue under Civil Rule 12(b)(1). The court found that the plaintiffs did not demonstrate a concrete injury necessary for standing.The United States Court of Appeals for the Sixth Circuit affirmed the district court's dismissal. The appellate court held that the legislators did not have standing because they did not represent the entire legislature or a controlling bloc within it. The court distinguished this case from precedents where entire legislatures or controlling blocs had standing to sue. The court emphasized that individual legislators generally lack standing to assert institutional injuries of the legislature. The court also noted that the legislators had not shown that their votes were nullified by the amendments, as required for standing under relevant Supreme Court precedents.The Sixth Circuit concluded that the legislators' claims did not meet the requirements for standing under Article III of the U.S. Constitution, as they did not suffer a concrete and particularized injury. The court affirmed the district court's dismissal of the case. View "Lindsey v. Whitmer" on Justia Law

Mark Blackwell criticized the city manager of Wayne, Michigan, leading the manager to complain to the police. Two officers convinced a prosecutor to charge Blackwell with stalking, but a judge acquitted him. Blackwell then sued the manager and officers, alleging they violated his First Amendment rights by inducing the prosecution in retaliation for his political speech. The district court found that Blackwell's complaint had enough facts to rebut the city officials' qualified-immunity defense at the pleading stage.The United States District Court for the Eastern District of Michigan denied the city officials' motion to dismiss, leading them to appeal. The district court refused to consider exhibits attached to the motion to dismiss and held that the complaint stated a plausible First Amendment retaliation claim. The court also found that qualified immunity would not protect the officials if Blackwell could prove his allegations.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court's decision to exclude the outside-the-complaint exhibits and found that Blackwell's complaint plausibly alleged a lack of probable cause for the stalking charge. The court held that the complaint sufficiently pleaded a First Amendment violation and that the law clearly established this violation. The court affirmed the district court's denial of the motion to dismiss, allowing Blackwell's claims to proceed. View "Blackwell v. Nocerini" on Justia Law

The case involves the Environmental Protection Agency (EPA) changing its air-quality standard for ozone under the Clean Air Act, which required states to amend their state plans. The EPA issued guidance memoranda to assist states, suggesting specific modeling and a minimum threshold for interstate emissions. Kentucky proposed a plan based on this guidance, but the EPA delayed action on the plan for two years and then disapproved it using different modeling and a lower threshold than initially recommended. Kentucky petitioned the court to vacate the EPA's disapproval.The EPA's disapproval of Kentucky's plan was challenged in the United States Court of Appeals for the Sixth Circuit. The EPA sought to transfer the case to the D.C. Circuit, arguing that the disapproval was a nationally applicable final action. The Sixth Circuit denied the motion, stating that the EPA's disapproval was not nationally applicable and was based on Kentucky's unique facts. The court also found that the EPA's action violated the Administrative Procedure Act (APA) by acting arbitrarily and inconsistently with its prior guidance.The Sixth Circuit held that the EPA's disapproval of Kentucky's plan was arbitrary and capricious. The court noted that the EPA failed to adequately explain its departure from prior guidance and did not consider Kentucky's reliance on the initial recommendations. The court vacated the EPA's disapproval of Kentucky's plan and remanded the case for further proceedings consistent with its opinion. The court emphasized the importance of consistency and the need for the EPA to justify its actions when changing its approach. View "Kentucky v. Environmental Protection Agency" on Justia Law

A group of car owners from ten states sued Nissan, alleging that certain models equipped with automatic electronic braking systems had a defect causing "phantom activations" at inappropriate times, such as at railroad crossings or in parking garages. The plaintiffs claimed this defect breached warranties, constituted fraud, violated consumer protection statutes, and unjustly enriched Nissan. They sought to certify ten statewide classes of owners or lessees of the affected models.The United States District Court for the Middle District of Tennessee certified the ten classes under Civil Rule 23(b)(3), finding that the plaintiffs had demonstrated common questions of law or fact. Nissan appealed, arguing that the classes did not meet the requirements for certification, particularly due to differences in the software updates that had been applied to the braking systems over time.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court had not conducted a rigorous analysis of the commonality requirement. The appellate court noted that the district court failed to consider the material differences in the software updates and how these differences might affect the existence of a common defect. Additionally, the district court did not analyze the elements of each state law claim to determine whether they could be resolved with common answers.The Sixth Circuit vacated the district court's certification of the classes and remanded the case for further proceedings. The appellate court emphasized the need for a detailed examination of the elements of each claim and the impact of the software updates on the alleged defect. The court also held that the district court must perform a Daubert analysis to ensure the reliability of the plaintiffs' expert testimony, which was critical to establishing the commonality of the defect across the different models and software versions. View "IN RE: NISSAN NORTH AMERICA,INC. LITIGATION" on Justia Law

Horace Crump, an inmate at Lakeland Correctional Facility in Michigan, filed a § 1983 lawsuit against several prison employees, alleging they withheld treatment for his multiple sclerosis. The key issue at this stage is whether Crump can proceed with his lawsuit without paying the filing fee upfront, as he sought to proceed in forma pauperis due to his inability to pay.The United States District Court for the Western District of Michigan dismissed Crump's complaint, citing the Prison Litigation Reform Act's three-strikes rule, which disqualifies prisoners from proceeding in forma pauperis if they have had three or more prior actions or appeals dismissed as frivolous, malicious, or for failing to state a claim. Crump appealed, disputing two of the three strikes counted against him.The United States Court of Appeals for the Sixth Circuit reviewed the case and focused on whether Crump's prior dismissals counted as strikes under the Act. The court found that Crump's previous cases, which included dismissals for failure to state a claim and decisions not to exercise supplemental jurisdiction over state-law claims, did not count as strikes. The court reasoned that the Act's language refers to entire actions being dismissed on specific grounds, not individual claims. Additionally, dismissals based on Eleventh Amendment immunity do not count as strikes under the Act.The Sixth Circuit vacated the district court's judgment and remanded the case for further proceedings, allowing Crump's lawsuit to proceed without the upfront payment of the filing fee. View "Crump v. Blue" on Justia Law

The plaintiffs, Glenn Bowles, Kenneth Franks, and Robert Gardner, challenged the constitutionality of Michigan's Court of Claims Act. Bowles and Franks, former police academy instructors, faced employment actions after allegations of misconduct, while Gardner, a former doctoral student, faced expulsion and subsequent employment issues due to his advocacy for migrant workers. They argued that the Act violated their Fourteenth Amendment rights by requiring Court of Appeals judges to serve on the Court of Claims, thus creating potential bias in appellate reviews and denying them jury trials.The United States District Court for the Eastern District of Michigan dismissed their complaint. The court found that the plaintiffs lacked standing as they did not demonstrate how the Court of Claims Act directly caused their injuries. Additionally, the court held that Bowles's claims were precluded due to a prior federal lawsuit and concluded that the plaintiffs' constitutional claims lacked merit.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit agreed that the plaintiffs lacked Article III standing. The court noted that the plaintiffs' injuries were not fairly traceable to the actions of Michigan's Governor and Attorney General, who were named as defendants. The court also found that the requested relief, an injunction against the enforcement of the Court of Claims Act, would not redress the plaintiffs' employment-related injuries. Consequently, the Sixth Circuit affirmed the district court's dismissal of the case on jurisdictional grounds, modifying the judgment to a dismissal without prejudice. View "Bowles v. Whitmer" on Justia Law

Nicholas and Stacy Boerson, owners of New Heights Farm I and II in Michigan, faced a disappointing corn and soybean harvest in 2019. They submitted crop insurance claims to Great American Insurance Company, which were delayed due to an ongoing federal fraud investigation. The Boersons sued Great American, the Federal Crop Insurance Corporation, and the U.S. Department of Agriculture for breach of contract, bad faith adjustment, and violations of insurance laws.The United States District Court for the Western District of Michigan dismissed the Boersons' claims. It ruled that claims related to Great American's nonpayment were unripe due to the ongoing investigation, while claims alleging false measurements and statements by Great American were ripe but subject to arbitration. The court also dismissed claims against the federal defendants on sovereign immunity grounds.The United States Court of Appeals for the Sixth Circuit affirmed the district court's dismissal. It held that the claims related to nonpayment were unripe because the insurance policy barred payment until the investigation concluded. The court also found that the arbitration agreement in the insurance policy covered the ripe claims against Great American, requiring those disputes to be resolved through arbitration. Additionally, the court ruled that sovereign immunity barred the claims against the federal defendants, as there was no clear waiver of immunity for constructive denial claims under the Federal Crop Insurance Act. View "New Heights Farm I, LLC v. Great American Insurance Co." on Justia Law

Lamonte Jackson-Gibson celebrated his birthday with friends, including his girlfriend, Toriel Dixon, in Detroit’s Greektown neighborhood. While listening to street musicians, Sergeant Reginald Beasley and other officers asked the group to move along. Jackson-Gibson questioned the order, leading to a verbal exchange and some physical pushing. Sgt. Beasley tased Jackson-Gibson in the back while he was embracing Dixon, and both were arrested. They were charged with obstructing or resisting a police officer, and Jackson-Gibson was also charged with disturbing the peace. A jury acquitted them of all charges.The United States District Court for the Eastern District of Michigan reviewed the case. Sgt. Beasley moved for summary judgment on the excessive-force claims, arguing for qualified immunity, but did not move for summary judgment on the wrongful-arrest claims. The district court granted summary judgment on Dixon’s excessive-force claim but denied it for Jackson-Gibson’s excessive-force claim. Sgt. Beasley’s motion to reconsider was also denied, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Sgt. Beasley’s challenge to the wrongful-arrest claims for lack of jurisdiction, as he did not seek qualified immunity for those claims in the lower court. The court affirmed the district court’s denial of qualified immunity on Jackson-Gibson’s excessive-force claim. The court held that a reasonable jury could find that Sgt. Beasley’s use of a taser was objectively unreasonable, as Jackson-Gibson’s alleged crimes were not severe, he did not pose an immediate threat, and he was not actively resisting arrest. The court also held that the right to be free from excessive force when not actively resisting was clearly established by 2019. View "Jackson-Gibson v. Beasley" on Justia Law

Timothy Hall participated in a protest in Detroit, where he was tackled and injured by a City of Detroit officer. Later, another officer ticketed him for disorderly conduct. Hall filed two lawsuits: one against the City of Detroit and another against the officers, claiming retaliation for exercising his First Amendment rights. The district court consolidated the suits, denied Hall’s request to extend the discovery period, granted summary judgment to the City, but denied the ticketing officer’s claim of qualified immunity.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the City of Detroit, dismissing Hall’s claims against the City. However, the court denied the ticketing officer’s motion for summary judgment on the grounds of qualified immunity, allowing Hall’s First Amendment retaliation claim to proceed. Hall appealed the denial of his motion to extend the discovery period and the summary judgment in favor of the City, while the ticketing officer appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of Hall’s motion to extend the discovery period and the grant of summary judgment to the City. However, the appellate court reversed the district court’s decision denying the ticketing officer’s motion for summary judgment on the grounds of qualified immunity. The court held that the officer was entitled to qualified immunity because it was not clearly established that issuing a ticket under the circumstances violated Hall’s First Amendment rights. The court emphasized that the officer acted on plausible instructions from a superior and had no reason to doubt the legitimacy of the order. View "Hall v. Navarre" on Justia Law

Two sisters from Guatemala fled to the United States in 2015 after gang members threatened to maim and kill them. They entered the U.S. without inspection and were placed in removal proceedings by the Department of Homeland Security (DHS). The sisters applied for asylum and withholding of removal, claiming they were targeted due to their membership in two particular social groups (PSGs): "Guatemalan female children without parental protection" and "the Rodas family."An immigration judge (IJ) denied their applications, finding that the harm they suffered did not rise to the level of persecution, that their proposed PSGs were not cognizable, and that there was no nexus between the harm and their family membership. The Board of Immigration Appeals (BIA) affirmed the IJ's decision, assuming without deciding that the harm constituted persecution but agreeing that the gang members were motivated by financial gain rather than animus toward the family.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Petitioners' arguments regarding due process and the "Guatemalan female children without parental protection" PSG were unreviewable because they were not raised before the BIA. However, the court held that the BIA's no-nexus determination regarding the "Rodas family" PSG was inconsistent with precedents. The court emphasized that persecutors can have mixed motives, and the BIA failed to consider whether the gang members' financial motives were intertwined with the Petitioners' family membership.The Sixth Circuit granted the petition for review in part, dismissed it in part, vacated the BIA's denial of asylum and withholding of removal, and remanded the case for further proceedings consistent with its opinion. The court instructed the BIA to reconsider the nexus between the harm and the Petitioners' family membership and to address whether the Guatemalan government was unable or unwilling to control the persecutors. View "Mazariegos-Rodas v. Garland" on Justia Law