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

The plaintiff alleged she experienced race and gender discrimination, harassment, and retaliation while employed at a facility operated by a subsidiary corporation in Michigan. Initially, she sued the parent corporation, claiming it was her employer and responsible for the alleged misconduct. The parent corporation contended she had sued the wrong entity and provided evidence that the subsidiary, not the parent, was her employer. The district court in the first case sided with the parent corporation, finding that it was not the plaintiff’s employer and that the complaint did not support a joint-employer theory or veil-piercing. After this ruling, the plaintiff filed a new suit against the subsidiary, asserting similar factual allegations and an additional hostile work environment claim under Michigan law.In the United States District Court for the Eastern District of Michigan, the subsidiary moved to dismiss the new case, arguing that claim preclusion barred the suit because the parent and subsidiary were in privity. The district court rejected the argument that the subsidiary had controlled the prior litigation but applied a “close-and-significant-relationship” test based on the parent-subsidiary relationship and equitable considerations. Concluding that privity existed and the other elements of claim preclusion were met, the district court granted the subsidiary’s motion to dismiss.The United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The appellate court held that the district court erred by applying the “close-and-significant-relationship” test for privity, rather than the six recognized exceptions to nonparty preclusion from Taylor v. Sturgell. None of the exceptions—pre-existing substantive legal relationship, control, or adequate representation—applied to the facts. Therefore, claim preclusion did not bar the plaintiff’s suit against the subsidiary. The Sixth Circuit reversed the district court’s decision. View "Williams v. Mastronardi Produce-USA, Inc." 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

The dispute centers on a property owner that purchased a vacant and dilapidated parcel in Nashville’s East Bank district, intending to redevelop it into a multi-family residential project in accordance with local zoning rules. The owner submitted a building permit application that, according to its allegations, fully complied with all applicable zoning requirements. However, in mid-2022, the local government placed an indefinite “development hold” on the property, effectively barring any consideration or approval of the permit. The stated reason was that authorities were assessing possible routes for a planned major roadway that might require acquisition of part of the property. As a result, the owner claims the property has become undevelopable and unsellable, resulting in millions of dollars in carrying costs.After unsuccessful efforts to have the hold lifted, the owner filed suit in state court, alleging violations of the Takings and Due Process Clauses of the U.S. Constitution and the Tennessee Constitution. The case was removed to the United States District Court for the Middle District of Tennessee, where the defendants moved to dismiss on several grounds, including untimeliness and qualified immunity. The district court, on its own initiative, dismissed the complaint for lack of “jurisdictional” ripeness, reasoning that there had been no final decision on the permit application.On appeal, the United States Court of Appeals for the Sixth Circuit considered only the ripeness issue. The court held that the owner’s claims were both constitutionally and prudentially ripe because the local government’s development hold constituted a definitive, final decision barring any development of the property. The appellate court reversed the district court’s dismissal and remanded the case for further proceedings on the remaining issues. View "SW Nashville EB Owner, LLC v. Metro. Gov't of Nashville & Davidson Cnty." on Justia Law

Several homeowners lost their properties through foreclosure after failing to pay property taxes to Oakland County, Michigan. Although the properties’ values exceeded the tax debts, the County retained all surplus equity rather than refunding the difference to the owners. The affected individuals, represented by attorney Scott Smith and later the McAlpine PC firm, brought suit alleging that this retention violated the Takings Clause of the U.S. Constitution.Both cases were initially dismissed by the United States District Court for the Eastern District of Michigan for failure to state a claim. The plaintiffs appealed. In the Hall case, the Pacific Legal Foundation represented the plaintiffs pro bono. The United States Court of Appeals for the Sixth Circuit reversed, holding that the County’s actions constituted a violation of the Takings Clause. The district court subsequently denied motions for class certification and the parties settled for $500,000. Plaintiffs then sought attorney fees totaling over $4.2 million, including hours spent on failed class certification and appeals largely handled by other counsel. The district court reduced the fee request by 40% and applied a 1.1 multiplier, awarding $1,361,476.51.The United States Court of Appeals for the Sixth Circuit reviewed the fee award for abuse of discretion and determined that the district court erred in several respects. The appellate court held that hours spent on failed class certification, litigation against other defendants, and certain other tasks were not properly billable and should have been categorically excluded. The court also found that the hours claimed for appellate work and by Mark McAlpine were grossly excessive, and that the district court failed to address the reasonableness of the hourly rates. The Sixth Circuit vacated the fee award and remanded, instructing the district court to recalculate fees with specific exclusions, a blended $325 hourly rate, and a 1.1 multiplier. No fees were awarded for the present appeal. View "Sinclair v. Meisner" on Justia Law

A Kentucky-based manufacturer entered into a sales representative agreement with a Minnesota-based company to facilitate sales of industrial parts in several Midwestern states. The contract included a choice of law clause specifying Kentucky law would govern disputes and permitted the manufacturer to terminate the relationship at its discretion. However, a pre-contract email from Minnesota’s representatives revealed their intent to disregard the Kentucky choice of law, planning instead to invoke the Minnesota Termination of Sales Representatives Act (MTSRA), which restricts termination and invalidates conflicting contract terms.After several years, the manufacturer issued a termination notice in line with the contract. The Minnesota company, shortly before the contract’s automatic renewal, claimed protection under the MTSRA and demanded $165,000, threatening litigation. The manufacturer responded by filing suit in the United States District Court for the Eastern District of Kentucky, seeking declaratory judgment that Kentucky law governed and asserting fraudulent inducement based on the Minnesota company’s misrepresentation of its intent to abide by the choice of law provision.The district court held that Kentucky law applied, rendering the MTSRA inapplicable, and granted declaratory judgment for the manufacturer. It permitted the fraudulent inducement claim to proceed to a jury, which found the Minnesota company liable, awarding nominal actual damages and $280,000 in punitive damages. The court denied post-trial motions challenging the verdict, jury instructions, evidentiary rulings, and the punitive damages award.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed. The Sixth Circuit held that Kentucky’s choice of law rules applied and that Kentucky had the most significant relationship to the contract, making the MTSRA inapplicable. The court upheld the jury’s finding of fraudulent inducement and found no abuse of discretion in the district court’s management of trial issues. The punitive damages award was found not to violate due process. View "Bonfiglioli USA, Inc. v. Midwest Engineered Components, Inc." on Justia Law

An elected official in a Tennessee city, after selling her home and residing outside city limits for an extended period, faced a legal challenge to her eligibility to serve based on the city’s residency requirement. The challenge was initiated after a citizen petition, supported by over two hundred signatures, prompted the district attorney to file a quo warranto petition seeking her removal from office. Although she later purchased an unimproved lot in the city and began construction of a new home, questions remained about her intent to return and her actual residency during the contested period.The Tennessee state court found her claims of living on the undeveloped property unconvincing but ultimately determined that her efforts to build a residence demonstrated just enough intent to return, allowing her to retain her office. Following this outcome, the official sued two citizens, the city, the mayor, and the city administrator in the United States District Court for the Eastern District of Tennessee, alleging First Amendment retaliation and conspiracy for their roles in initiating the removal proceedings, along with a state law malicious prosecution claim. The district court granted summary judgment to the defendants on the federal claims, holding that she failed to show a conspiracy or retaliation connected to her protected speech, and declined to exercise jurisdiction over the state law claim.On appeal, the United States Court of Appeals for the Sixth Circuit held that, when a claim of First Amendment retaliation is based on the initiation of a civil action such as a quo warranto petition, the plaintiff must show a lack of probable cause for that action. The court concluded that probable cause existed to support the quo warranto petition, as there were reasonable grounds to doubt the official’s residency. Therefore, the court affirmed summary judgment for the defendants and found no abuse of discretion in the district court’s handling of discovery deadlines. View "Amacher v. City of Tullahoma" on Justia Law

A lawful permanent resident who had fled civil war in Liberia and become a U.S. resident in 2016 was convicted twice under Michigan law for possessing a loaded firearm in a vehicle, and later for embezzlement. Following his most recent conviction, the Department of Homeland Security initiated removal proceedings. At his removal hearing, his attorney conceded removability and applied for cancellation of removal. The Immigration Judge (IJ) denied this relief, focusing solely on the discretionary factors, as eligibility was uncontested.The petitioner appealed to the Board of Immigration Appeals (BIA), arguing that the IJ should have granted cancellation based on the equitable balance of factors. The BIA affirmed the IJ’s decision. Subsequently, represented by new counsel, the petitioner filed a motion to reconsider and reopen, alleging ineffective assistance by prior counsel and challenging whether his Michigan firearm conviction qualified as a removable firearms offense under federal law. He included supporting documents for his ineffective assistance claim. The Department of Homeland Security also moved to reopen and dismiss the proceedings, citing changed circumstances. The BIA denied both motions, finding the petitioner had not complied with procedural requirements for ineffective assistance claims—specifically, he failed to provide evidence that notice and a bar complaint had been sent. The BIA also denied the government’s motion, noting it lacked explanation or supporting new facts.The United States Court of Appeals for the Sixth Circuit reviewed the case. It dismissed the petitioner’s first petition, holding that his arguments were either unexhausted or jurisdictionally barred. The court denied the second petition, finding the BIA did not abuse its discretion in denying relief for ineffective assistance due to lack of procedural compliance, and also properly denied the government’s motion to reopen and dismiss for lack of supporting evidence. View "Morris v. Blanche" on Justia Law

The United States government, acting through the Attorney General, demanded that the Michigan Secretary of State provide an unredacted copy of Michigan’s statewide voter registration list, which includes sensitive personal information like dates of birth, driver’s license numbers, and partial social security numbers. The Secretary of State provided only a version with personal information redacted, citing concerns about the lack of statutory authority for the federal government’s request. The government then filed suit, seeking to compel production of the unredacted list.In the United States District Court for the Western District of Michigan, the Secretary of State, the State of Michigan, and certain intervenors moved to dismiss the complaint. The district court granted the motions, concluding that Title III of the Civil Rights Act of 1960 did not authorize the federal government’s demand for the unredacted voter file. The government appealed, contesting only the dismissal of its claim under Title III.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The court held that Michigan’s qualified voter file is not a “record” that “comes into the possession” of the Secretary of State within the meaning of Title III, as it is an internally generated database rather than a record acquired from a third party. The court also determined that the government failed to comply with Title III’s procedural requirements for making such a demand, as its letters did not contain both the basis and the purpose for the request as required by statute. Accordingly, the Sixth Circuit affirmed the judgment of the district court, holding that the Secretary of State did not violate Title III by refusing to provide the unredacted voter file. View "United States v. Benson" on Justia Law

Several Michigan residents purchased expensive solar-panel systems from a company that promised substantial reductions in their electricity bills. The company’s advertising, prepared in part by entities connected to Trivest Partners, promoted significant savings and government payments, but the plaintiffs experienced little to no reduction in their bills and, in some cases, saw increases. The company, which operated in both Michigan and Florida, later went bankrupt. Alleging fraud and racketeering violations, the plaintiffs brought a civil RICO action and a Michigan Consumer Protection Act claim against Trivest Partners, its affiliates (all Florida entities), and the company founder.In the United States District Court for the Eastern District of Michigan, the two Florida-based Trivest defendants moved to dismiss for lack of personal jurisdiction, arguing that the civil RICO statute did not allow them to be sued in Michigan, as a court in Florida could exercise jurisdiction over all defendants. The district court denied the motion, holding that several practical factors—including the pending status of the case in Michigan, local counsel, and comparative convenience—favored retaining jurisdiction. The plaintiffs later added additional Trivest-related defendants, also Florida citizens, with the court again finding personal jurisdiction.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s interpretation of 18 U.S.C. § 1965(b) de novo. The appellate court held that the district court’s reasons, grounded in convenience and practical considerations, were insufficient as a matter of law to satisfy the “ends of justice require” standard under § 1965(b). The Sixth Circuit concluded that interests of convenience alone cannot justify asserting personal jurisdiction over defendants with no minimum contacts to the forum. The court reversed the district court’s order denying dismissal and vacated the order denying the Trivest defendants’ motions to compel arbitration. View "Hall v. Trivest Partners L.P." on Justia Law

During the COVID-19 pandemic, the Superintendent of Hamtramck Public Schools took voluntary medical leave under the Family and Medical Leave Act (FMLA). When she prepared to return, the school district placed her on paid administrative leave pending an investigation into alleged misconduct. While on leave, she filed charges of discrimination with government agencies and was not allowed to return to her duties for over a year. She alleged that these actions were the result of retaliation and discrimination after she had involuntarily reassigned several teachers, which had sparked conflict with the school board and teachers’ union.While still on paid leave, the Superintendent filed suit in the United States District Court for the Eastern District of Michigan against the school district, several board members, and the teachers’ union, alleging multiple claims including discrimination based on disability, sex, and national origin, as well as retaliation. She attempted to amend her complaint multiple times. The district court denied her motion to file a Fourth Amended Complaint, holding that the proposed amendments were futile, and granted the defendants’ motions to dismiss the original complaint with prejudice. She then appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of leave to amend de novo. The appellate court held that the district court erred in finding that her proposed claims for FMLA retaliation and Title IX sex discrimination were futile. The Sixth Circuit concluded that her allegations plausibly stated claims under both statutes, applying the correct legal standards. The appellate court vacated the district court’s dismissal, reversed its futility determination, and remanded the case so the plaintiff could proceed with her amended complaint. View "Ahmed v. Hamtramck Public Schools" on Justia Law