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

Tammy Livingston, individually and as a beneficiary and co-trustee of the Livingston Music Interest Trust, sued her mother, Travilyn Livingston, over the termination of copyright assignments and associated royalties for songs authored by Jay Livingston. Jay had assigned his copyright interests in several songs to a music publishing company owned by Travilyn. Travilyn later invoked her statutory right to terminate these copyright grants and filed termination notices with the U.S. Copyright Office. Tammy challenged these terminations, claiming her rights as a beneficiary were affected.The United States District Court for the Middle District of Tennessee dismissed Tammy's complaint, holding that it failed to state a claim. Tammy appealed the decision, arguing that the termination notices were ineffective, defective, or invalid, and that she retained a state law right to receive royalties from the songs covered by the terminated agreements.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal. The court held that the 2003 California probate court order, which declared that the Family Trust held no ownership interests in Jay's copyrights, precluded Tammy's claims. The court also found that Jay had validly executed the copyright grants as an individual, not as a trustee, and that Travilyn owned Jay Livingston Music at the time of the assignments. Additionally, the court rejected Tammy's arguments regarding the termination notices' compliance with federal requirements, noting that she failed to plead specific factual allegations for most of the notices. Finally, the court held that Tammy did not identify a state law basis for her claim to royalties, thus failing to meet the pleading standards under Civil Rule 12(b)(6). View "Livingston v. Jay Livingston Music, Inc." on Justia Law

Lester Warren Martin, a renowned pediatric surgeon and successful investor, passed away in 2020, leaving behind a substantial estate. He had created a revocable trust in 1990, which was to be distributed equally among his five children. After one of his daughters, Sarah Stewart, passed away, her share was to be divided between her two children, Daniel Stewart and Rachel Kosoff. In 2018, Lester gave his son, David Martin, power of attorney and made him the trustee of the revocable trust. David distributed $13,930,000 from the trust, mostly to Lester’s four living children, with a smaller portion to Daniel and Rachel.The United States District Court for the Southern District of Ohio held that David breached his fiduciary duties by making distributions without specific written authorization from Lester, as required by the trust. The court granted summary judgment for the plaintiffs on liability and dismissed their remaining claims. A jury trial determined that David owed Daniel and Rachel $2,086,000 in damages. David later filed a motion for relief from judgment, arguing that the court lacked jurisdiction because the plaintiffs did not have a legal right to sue under Ohio law. The district court agreed and dismissed the case.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that Daniel and Rachel had Article III standing, as they alleged a concrete monetary injury traceable to David’s actions and redressable by the court. The appellate court vacated the district court’s order granting relief from judgment and remanded the case for the district court to rule on David’s Rule 50(b) motion for judgment as a matter of law regarding the necessity of expert testimony to prove damages. The appellate court affirmed the denial of David’s motion in limine to exclude the plaintiffs’ damages testimony. View "Stewart v. Martin" on Justia Law

The plaintiff, a Belgian company, agreed to ship car parts made in Mexico to a Mexican plant operated by the defendants, a Delaware LLC and a Delaware corporation. The initial contract documents included a forum-selection clause pointing to a Mexican venue. However, the plaintiff later sued in Michigan, alleging that the parties had switched to a Michigan forum-selection clause during their transactions. The defendants moved to dismiss the suit under Federal Rule of Civil Procedure 12(b)(6) and the forum non conveniens doctrine, arguing that the Mexican forum-selection clause applied.The United States District Court for the Eastern District of Michigan granted the defendants' Rule 12(b)(6) motion, dismissing the suit without conducting a forum non conveniens analysis. The court found that the forum-selection clause in the initial contract documents, which pointed to a Mexican venue, was controlling.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the complaint plausibly alleged that the parties had switched to a Michigan forum-selection clause. The court noted that a factual dispute existed over which forum-selection clause applied to the plaintiff’s breach-of-contract claims. The court held that this venue issue could not be resolved on the pleadings under Rule 12(b)(6) or under the forum non conveniens doctrine without factual findings. Therefore, the Sixth Circuit reversed the district court's decision and remanded the case for further proceedings to resolve the factual disputes regarding the applicable forum-selection clause. View "VCST Int'l B.V. v. BorgWarner Noblesville, LLC" on Justia Law

In late July 2022, an unprecedented flood destroyed numerous homes and properties in Eastern Kentucky. Plaintiffs, who suffered losses, filed a lawsuit against Pine Branch Mining, LLC, alleging that the company violated Kentucky mining regulations in maintaining a surface mine property near their lands, resulting in negligence per se. They claimed that Pine Branch's infractions substantially contributed to the flooding.The United States District Court for the Eastern District of Kentucky excluded the opinion of Plaintiffs' sole causation expert, Scott Simonton, under Federal Rule of Evidence 702 and Federal Rule of Civil Procedure 26(a)(2)(B). The court found that Simonton's report was not based on sufficient facts or data specific to the mining sites in question, lacked reliable principles and methods, and failed to consider alternative causes of the damage. Consequently, the district court granted summary judgment to Pine Branch, concluding that Plaintiffs could not establish a prima facie case of negligence per se without competent expert proof.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the district court did not abuse its discretion in excluding Simonton's testimony, as it was deficient in reliability and completeness. Without Simonton's expert opinion, Plaintiffs lacked sufficient evidence to prove causation, an essential element of their negligence per se claim. The court held that the remaining evidence was insufficient to create a genuine dispute of material fact, and thus, summary judgment in favor of Pine Branch was appropriate. View "Baker v. Blackhawk Mining, LLC" on Justia Law

Robert Carbone, a Connecticut resident, sued two Swiss organizations and several individuals from California, Illinois, and Switzerland for defamation and other tortious conduct. Carbone, a member of the two Swiss organizations, claimed that the defendants used websites to publish defamatory statements about him and facilitate his removal from the organizations. He filed the lawsuit in Ohio, arguing that the defamatory statements passed through servers located in Ohio, which hosted the organizations' websites.The United States District Court for the Southern District of Ohio dismissed Carbone's complaint for lack of personal jurisdiction. The court found that Carbone failed to establish that the defendants had sufficient contacts with Ohio to justify the court's jurisdiction over them. The defendants had not purposefully availed themselves of the privilege of acting in Ohio, as the servers' location in Ohio was chosen by third parties, not the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the defendants did not purposefully avail themselves of the privilege of acting in Ohio, as their only connection to the state was the location of the servers, which was a decision made by third parties. The court also found that Carbone's claims did not arise from the defendants' activities in Ohio, as the allegedly defamatory statements were not directed at Ohio or its residents. Therefore, the exercise of personal jurisdiction over the defendants in Ohio would not comply with the Due Process Clause. View "Carbone v. Kaal" on Justia Law

A fifty-nine-year-old General Manager (GM) at a Chili’s restaurant in Nashville, Tennessee, was terminated and replaced by a thirty-three-year-old with no managerial experience. The employer, Brinker International, Inc., claimed the termination was due to the GM creating a toxic "culture" and not "living the Chili’s way," despite the restaurant being one of the top performers in the market. The GM alleged that the termination was due to age discrimination, as he was the oldest manager in the region and believed Brinker was systematically replacing older employees with younger ones.The United States District Court for the Middle District of Tennessee granted summary judgment in favor of Brinker, accepting the company's explanation of "culture" as a legitimate, non-discriminatory reason for the termination. The court found that the GM could not sufficiently rebut this explanation to show it was pretext for age discrimination. The court also granted in part and denied in part the GM's motion for sanctions due to Brinker’s spoliation of evidence, awarding fees and costs but not excluding the TMR Report, which documented the termination decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the TMR Report could not be authenticated under Federal Rule of Evidence 901 and was therefore inadmissible. The court vacated the district court’s order on sanctions and instructed it to consider whether additional sanctions beyond fees and costs were appropriate. The appellate court also reversed the district court’s grant of summary judgment for Brinker, finding that the GM had provided sufficient evidence to rebut Brinker’s explanation and create a genuine issue of material fact regarding age discrimination. The court affirmed the district court’s denial of the GM’s motion for summary judgment. View "Kean v. Brinker Int'l, Inc." on Justia Law

Brian Lyngaas, a dentist, sued United Concordia Companies, Inc. (UCCI) for sending unsolicited faxed advertisements in violation of the Telephone Consumer Protection Act (TCPA). Lyngaas, through his dental practice, was part of UCCI’s Fee for Service Dental Network, which included a “Value Add Program” (VAP) offering discounts from third-party vendors. UCCI sent three faxes promoting these discounts, which Lyngaas claimed were unsolicited advertisements.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of UCCI, ruling that the faxes were not advertisements under the TCPA because UCCI’s profit motive was too remote. Lyngaas appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and reversed the district court’s decision. The appellate court held that UCCI’s faxes were advertisements under the TCPA because they facially promoted third-party products as part of exclusive marketing agreements, and UCCI had a sufficiently direct profit motive. The court emphasized that TCPA liability falls on the sender of the fax, not necessarily the seller of the advertised product. The court also noted that Lyngaas could not proceed with claims regarding a fax he did not receive. The case was remanded for further proceedings consistent with this opinion. View "Brian J. Lyngaas, D.D.S., P.L.L.C. v. United Concordia Co." on Justia Law

Fire-Dex, a manufacturer of personal protective equipment for firefighters, faced lawsuits from firefighters and their spouses alleging exposure to carcinogens from Fire-Dex's products. These lawsuits were consolidated in multidistrict litigation in South Carolina. Fire-Dex had general commercial liability insurance policies with Admiral Insurance Company and requested Admiral to defend and indemnify it against the lawsuits. Admiral refused, leading to a declaratory judgment action in federal court in Ohio, where the district court declined to exercise jurisdiction.The United States District Court for the Northern District of Ohio initially had diversity jurisdiction over Admiral's declaratory judgment action but chose to abstain from exercising it, a decision affirmed by the Sixth Circuit. Subsequently, Fire-Dex filed a lawsuit in Ohio state court seeking a declaration that Admiral must defend and indemnify it, along with compensatory and punitive damages for breach of contract and bad faith. Admiral removed the case to federal court and filed counterclaims for declaratory judgment. Fire-Dex moved to remand the case to state court.The United States Court of Appeals for the Sixth Circuit reviewed the district court's decision to remand the declaratory claims and stay the damages claims. The Sixth Circuit held that the district court erred in abstaining from the declaratory claims under Thibodaux abstention, as the case did not involve unsettled questions of state law intimately involved with state sovereignty. The court also found that abstaining from the declaratory claims was an abuse of discretion because the declaratory and damages claims were closely intertwined, and no traditional abstention doctrine applied to the damages claims. The Sixth Circuit vacated the district court's order and remanded for further proceedings. View "Fire-Dex, LLC v. Admiral Insurance Co." on Justia Law

A high school student, Eszter Pryor, trained and competed with the Ohio State Diving Club at The Ohio State University (OSU). In the summer of 2014, when she was sixteen, her diving coach, William Bohonyi, sexually abused her. Pryor alleged that OSU was aware of the abuse by August 2014, as they fired Bohonyi following an internal investigation. Pryor filed a Title IX lawsuit against OSU in January 2022, claiming the university was deliberately indifferent to a sexually hostile culture and her abuse.The United States District Court for the Southern District of Ohio dismissed Pryor's claim, ruling it was time-barred by the statute of limitations. OSU had argued that the applicable statute of limitations was two years, as per Ohio Revised Code § 2305.10(A), and the district court agreed, granting summary judgment in favor of OSU based on the expiration of the limitations period.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that the correct statute of limitations for Title IX claims in Ohio is the two-year period for personal injury actions under Ohio Revised Code § 2305.10(A). The court rejected Pryor's argument that a twelve-year limitations period for child sex-abuse claims under Ohio Revised Code § 2305.111(C) should apply. The court emphasized the importance of uniformity and predictability in applying the statute of limitations and noted that Pryor's claim accrued when she turned eighteen in July 2015, giving her until July 2017 to file her lawsuit. Since she filed in January 2022, her claim was indeed time-barred. View "Pryor v. The Ohio State University" on Justia Law

In this case, Whitney Hodges, representing the estate of her late daughter Honestie Hodges, alleges that on December 6, 2017, Grand Rapids Police Department officers detained Honestie, an eleven-year-old African American girl, at gunpoint, handcuffed her, and placed her in a police car. The officers were searching for a stabbing suspect who did not match Honestie’s description. Honestie was not armed, did not pose a threat, and did not attempt to flee. The complaint asserts that the officers lacked probable cause or reasonable suspicion to detain Honestie and used excessive force in doing so.The United States District Court for the Western District of Michigan partially denied the officers' motion to dismiss on qualified-immunity grounds. The district court found that the complaint plausibly alleged violations of Honestie’s Fourth Amendment rights, including unreasonable search and seizure, false imprisonment, and excessive force. The court declined to consider video evidence and police reports provided by the officers, determining that these materials did not blatantly contradict the complaint’s allegations and were subject to reasonable dispute.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. The court affirmed the district court’s order, agreeing that the complaint plausibly alleged that the officers violated Honestie’s clearly established rights. The Sixth Circuit held that the officers’ actions, as alleged, lacked reasonable suspicion or probable cause and involved excessive force. The court dismissed the officers' appeal to the extent it sought to resolve disputed factual issues, emphasizing that such issues should be addressed after discovery. View "Hodges v. City of Grand Rapids, Mich." on Justia Law