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

The case involves Dr. Euna McGruder, who was terminated from her position as the Executive Officer of Priority Schools for the Nashville public school system, operated by Metro Nashville, after she investigated allegations of racial discrimination at a Nashville middle school. McGruder sued Metro Nashville in 2017, alleging that her termination constituted illegal retaliation in violation of Title VII. In 2021, a jury awarded McGruder $260,000 for her claim, and the district court ordered Metro Nashville to reinstate her to her previous position.After the trial, Metro Nashville discovered that McGruder had failed to disclose the existence of her Title VII claim to the bankruptcy court when she filed for Chapter 7 bankruptcy in 2018. Metro Nashville argued that McGruder's claims should be barred by judicial estoppel due to her failure to disclose her cause of action against Metro Nashville in her bankruptcy filing. The district court concluded that it could not exercise jurisdiction over Metro Nashville’s judicial estoppel claim, given that Metro Nashville’s earlier notice of appeal had divested the court of jurisdiction over the case.The United States Court of Appeals for the Sixth Circuit affirmed the district court's reinstatement order and dismissed Metro Nashville's appeal for lack of jurisdiction. The court held that judicial estoppel does not bar McGruder's reinstatement. The court also found that the district court did not abuse its discretion in ordering McGruder's reinstatement. The court did not have jurisdiction to apply judicial estoppel to the non-final and therefore non-appealable jury award, forthcoming back pay trial, or award of attorneys’ fees. View "McGruder v. Metro. Gov't of Nashville" on Justia Law

The case involves a dispute between Firexo Group Limited (FGL), a British company that manufactures fire extinguishers, and Firexo, Inc., a Florida-based company that was created to sell FGL's products in the United States. Scot Smith, a resident of Ohio, purchased 70% of Firexo, Inc. from FGL under a Joint Venture Agreement (JVA). The JVA included a forum-selection clause designating England or Wales as the exclusive jurisdiction for any disputes arising from the agreement. Firexo, Inc., which was not a signatory to the JVA, later sued FGL in an Ohio court over issues with the fire extinguishers. FGL sought to dismiss the case based on the forum-selection clause in the JVA.The district court granted FGL's motion to dismiss, applying the "closely related" doctrine. This doctrine allows a non-signatory to a contract to be bound by a forum-selection clause if the non-signatory is sufficiently closely related to the contract. The district court found that Firexo, Inc. was closely related to the JVA and therefore subject to the forum-selection clause. Firexo, Inc. appealed this decision, arguing that the district court applied the wrong law and analytical approach in determining the applicability of the contract.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The appellate court agreed with Firexo, Inc. that the district court had applied the wrong law. The court held that the "closely related" doctrine, a federal common law rule, should not have been used to interpret the JVA's forum-selection clause. Instead, the court should have applied the law specified in the JVA, which was English law. Under English law, contracts do not apply to non-signatories unless certain exceptions apply, none of which were present in this case. Therefore, the forum-selection clause in the JVA did not apply to Firexo, Inc., and the case was remanded for further proceedings. View "Firexo, Inc. v. Firexo Group Limited" on Justia Law

The case involves Dennis Neate, a former employee of the James B. Oswald Company (Oswald), an insurance firm. Neate left Oswald to work for Hylant Group, Inc., another insurance firm, and some of his clients followed him. Oswald accused Neate of violating his non-solicitation agreement and sued in federal district court. The court issued a preliminary injunction ordering Neate and others to comply with Oswald’s non-solicitation agreement. Neate appealed.Previously, the district court granted a preliminary injunction after an evidentiary hearing. The injunction prohibited Neate and others from violating their agreements with Oswald, retaining or using Oswald's confidential information, and soliciting or accepting business from Oswald's clients. The injunction also required all defendants to return all of Oswald's property.The United States Court of Appeals for the Sixth Circuit vacated and remanded the case. The court found that the district court failed to properly apply Ohio law in determining the reasonableness of the non-solicitation agreement. The court also found that the injunction did not meet the specificity requirements of Federal Rule of Civil Procedure 65(d)(1), as it incorporated the non-solicitation agreement by reference. However, the court agreed with the district court that Oswald had shown a likelihood of success on its trade-secrets claims. View "James B. Oswald Co. v. Neate" on Justia Law

The plaintiffs, Reverend Kenneth Simon, Reverend Lewis W. Macklin, II, and Helen Youngblood, collectively known as the "Simon Parties," filed a lawsuit against the Ohio Redistricting Commission and several of its members. They alleged that Ohio's congressional districts violated section 2 of the Voting Rights Act, the First Amendment, the Fourteenth Amendment, and the Fifteenth Amendment. The Simon Parties requested a three-judge court under 28 U.S.C. § 2284, which the Ohio Redistricting Commission opposed, and moved to dismiss the complaint.The district court denied the motion to convene a three-judge court and granted the motions to dismiss. The court also denied all other pending motions. The Simon Parties appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the district court incorrectly determined that the Simon Parties' Fourteenth Amendment claim did not raise a substantial federal question for jurisdictional purposes. The court stated that the Simon Parties' allegations on this claim were sufficient to establish federal jurisdiction. The court concluded that the district court lacked jurisdiction as a single judge to adjudicate any other pending motion because it was required to convene a three-judge court under 28 U.S.C. § 2284.The court reversed the district court's order denying the motion for a three-judge court, vacated the district court's orders granting the motions to dismiss and denying the motion for temporary restraining order and motion for class certification, and remanded the case to the district court with instructions for it immediately to initiate the procedures to convene a three-judge court under 28 U.S.C. § 2284. View "Simon v. DeWine" on Justia Law

This case pertains to an alleged copyright infringement involving software code used in an industrial control system. The plaintiffs, RJ Control Consultants, Inc. and its sole shareholder, Paul Rogers, appealed the district court’s exclusion of their proposed expert and the granting of summary judgment to the defendants, Multiject, LLC; its sole owner, Jack Elder; and RSW Technologies, LLC. The U.S Court of Appeals for the Sixth Circuit held that the district court did not abuse its discretion in excluding the plaintiffs’ proposed expert or in granting summary judgment to the defendants. The plaintiffs had failed to properly disclose their expert as required and did not produce an expert report. Consequently, they could not offer expert evidence to rebut the defendants' evidence. Furthermore, they could not create a genuine dispute of fact about the protectability of the software code, a crucial factor in their copyright infringement claim. Therefore, the district court's judgment was affirmed. The court also vacated its prior decision in RJ Control Consultants, Inc. v. Multiject, LLC, 981 F.3d 446 (2020), due to lack of appellate jurisdiction at the time of that decision. View "R.J. Control Consultants, Inc. v. Multiject, LLC" on Justia Law

In this case, a taxi driver, Lufti Said Saalim, sued Walmart and several individuals, including deputy sheriffs, alleging violations of his Fourth and Fourteenth Amendment rights and state law claims following an incident at a Walmart in Toledo, Ohio. Saalim claimed that while waiting for his passengers at a loading zone, he was approached by a Walmart employee and subsequently by Deputy Sheriff Jeffrey Bretzloff, who was working as a private security guard for Walmart. Saalim alleged that Bretzloff used excessive force during the encounter, including pulling him out of his cab and using a taser on him.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision that granted Bretzloff qualified immunity on Saalim's Fourth Amendment claim. The court held that Saalim plausibly alleged that Bretzloff's use of force was unreasonable and violated the Fourth Amendment. The court also found that this right was clearly established at the time of the incident.However, the court affirmed the district court's dismissal of Saalim's Fourteenth Amendment claim, agreeing that it was identical to his Fourth Amendment claim. The court also affirmed the dismissal of Saalim's state law claims of assault, battery, intentional infliction of emotional distress, false arrest, and false imprisonment, as they were barred by the statute of limitations.The court remanded the case for further proceedings on Saalim's Fourth Amendment claim against Bretzloff; his § 1983 municipal liability claim against Sheriff Navarre; and his state law claims of negligent hiring, supervision, training, and retention and vicarious liability against the Walmart Defendants and McNett. View "Saalim v. Walmart, Inc." on Justia Law

FedEx Ground Package Systems, Inc. (FXG) filed a lawsuit against Route Consultant, Inc., alleging that the latter company had made nine false or misleading statements about FXG's business practices. FXG contended that these statements were intended to foster discontent between FXG and its contractors, thereby damaging FXG and benefiting Route Consultant. The suit was brought under both the Lanham Act's false advertising provision and the Tennessee Consumer Protection Act's statutory disparagement provision.The United States Court of Appeals for the Sixth Circuit confirmed the lower court's decision to dismiss the case. The court found that FXG had failed to plausibly allege that Route Consultant made a single false or misleading statement. The court emphasized that only statements of fact--not opinions, puffery, or rhetorical hyperbole--are actionable under the false advertising provision of the Lanham Act. Moreover, a plaintiff must plead and prove the literal falsity of the defendant's statement or demonstrate that the statement is misleading. FXG's complaint did not meet these standards.The court also held that FXG's claim under the Tennessee Consumer Protection Act failed for the same reasons as its Lanham Act claim. Thus, the court affirmed the district court's dismissal of FXG's lawsuit against Route Consultant. View "FedEx Ground Package Systems, Inc. v. Route Consultant, Inc." on Justia Law

A medical malpractice lawsuit was filed by Dwan and Aaron Bray, individually and on behalf of their minor child, against Dr. Timothy J. Thress and various other medical entities. The suit, which was initially filed in state court, related to alleged negligence in Dwan Bray's prenatal care and the subsequent birth of their child. However, Thress was employed by a federally funded health center during his treatment of Bray. Under the Federally Supported Health Centers Assistance Act (FSHCAA), the lawsuit was removed to federal court and the United States was substituted as the defendant.The U.S. government moved to dismiss the case, arguing that the plaintiffs failed to satisfy the Federal Tort Claims Act’s (FTCA) administrative exhaustion requirement. The plaintiffs countered by moving to remand the action to state court, arguing that the FSHCAA did not apply. The district court denied both of plaintiffs’ motions, finding the FSHCAA applicable and any attempt to amend plaintiffs’ complaint futile. The district court dismissed plaintiffs’ FTCA claim without prejudice and remanded plaintiffs’ claims against the remaining defendants to state court. The plaintiffs appealed the district court’s denial of their motion to remand and its dismissal of their FTCA claim.The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decisions. It held that Thress's conduct was covered by the FSHCAA, and that the plaintiffs' attempts to amend their complaint were futile since they had failed to exhaust their administrative remedies under the FTCA before instituting the lawsuit. View "Bray v. Bon Secours Mercy Health, Inc." on Justia Law

The court case involves Ferrellgas, L.P., which was appealing against an order enforcing a subpoena issued by the Equal Employment Opportunity Commission (EEOC). The subpoena was part of an EEOC investigation into a discrimination charge filed by an employee, alleging that Ferrellgas had engaged in discriminatory hiring, pay, and termination practices.Ferrellgas contended that the subpoena was improperly served, was facially invalid due to procedural errors, was overly broad, and would impose an undue burden. Ferrellgas also argued that the subpoena sought information on hiring practices, which was irrelevant to the specific discrimination charge. The United States Court of Appeals for the Sixth Circuit rejected all of Ferrellgas's arguments.The Court found that the subpoena was served properly, despite Ferrellgas's claims to the contrary. It also ruled that the procedural errors in the subpoena were harmless and did not preclude its enforcement. The Court concluded that the subpoena was not overly broad, as the information sought could shed light on the alleged discriminatory practices. The Court also held that Ferrellgas failed to demonstrate that complying with the subpoena would impose an undue burden.In conclusion, the Court affirmed the district court's order enforcing the EEOC's subpoena, deciding that the lower court did not abuse its discretion in doing so. View "EEOC v. Ferrellgas, L.P." on Justia Law

In this case, a prisoner, Kyle Brandon Richards, appealed a district court's decision to dismiss his civil rights suit under 42 U.S.C. § 1983. The lawsuit was dismissed because Richards reportedly failed to exhaust his administrative remedies. The plaintiff alleged sexual harassment, retaliation, and destruction of property by Resident Unit Manager Thomas Perttu. Specifically, Richards claimed that Perttu prevented him from filing grievances related to the alleged abuse by destroying or ripping them up.The defendant, Perttu, moved for summary judgment, arguing that Richards had failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a). The district court denied the motion due to questions of fact. After an evidentiary hearing, a magistrate judge recommended that the district court find that Richards had failed to exhaust his administrative remedies. Richards appealed, alleging errors by the district court, bias by the magistrate judge, and the need for a free transcript of the evidentiary hearing.The United States Court of Appeals for the Sixth Circuit addressed whether the district court should have ordered an evidentiary hearing to decide the disputed questions of fact intertwined with the exhaustion issue. The Court of Appeals found that the Seventh Amendment required a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff’s substantive case. Therefore, the Court of Appeals reversed the judgment of the district court and remanded the case for further proceedings. View "Richards v. Perttu" on Justia Law