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

The plaintiffs, who regularly engage in cryptocurrency transactions, challenged amendments to 26 U.S.C. § 6050I, which now require reporting certain cryptocurrency transactions to the federal government. They argued that the law violates their constitutional rights under the Fourth, First, and Fifth Amendments, and exceeds Congress's enumerated powers. The plaintiffs claimed that the law's requirements would force them to disclose private information, incur compliance costs, and potentially expose them to criminal penalties.The United States District Court for the Eastern District of Kentucky dismissed the case, finding that it lacked jurisdiction to consider the merits of the plaintiffs' claims. The court ruled that the claims were either not ripe for adjudication or that the plaintiffs lacked standing. Specifically, the court found that the Fourth Amendment claim was not ripe because the law was not yet effective and the Department of Treasury was still developing rules. The First Amendment claim was dismissed for lack of standing, as the court deemed the plaintiffs' injuries too speculative. The court also found the Fifth Amendment vagueness claim unripe due to pending regulatory action, and the enumerated-powers claim unripe for similar reasons. The Fifth Amendment self-incrimination claim was dismissed as not ripe because the plaintiffs had not yet asserted the privilege.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court erred in dismissing the enumerated-powers, Fourth Amendment, and First Amendment claims. The appellate court held that these claims were ripe for review and that the plaintiffs had standing. The court noted that the plaintiffs, as direct objects of the law, would indeed be subject to the reporting requirements and incur compliance costs, thus suffering an injury in fact. The court affirmed the district court's dismissal of the Fifth Amendment vagueness and self-incrimination claims as not ripe. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Carman v. Yellen" on Justia Law

In 1984, Richard Wershe, Jr., at fourteen, was recruited by the FBI as a drug informant. Over the next few years, he was involved in dangerous drug operations under the direction of federal and state officers. In 1987, Wershe was arrested and convicted of possessing a large quantity of cocaine, receiving a life sentence without parole, which was later amended to allow parole eligibility. While incarcerated, he cooperated with law enforcement in various investigations, including "Operation Backbone" and a grand jury against the "Best Friends" gang, based on promises of assistance with his parole. Despite his cooperation, Wershe was denied parole in 2003 and was only released in 2017, subsequently serving time in Florida for an unrelated charge until his release in 2020.Wershe filed two lawsuits: one in July 2021 against the City of Detroit and various federal and state officials under 42 U.S.C. § 1983 and Bivens, and another in October 2022 against the United States under the Federal Tort Claims Act (FTCA). He alleged constitutional violations and tort claims related to his time as a juvenile informant and subsequent parole denial. The United States District Court for the Eastern District of Michigan dismissed both lawsuits with prejudice, ruling that Wershe’s claims were time-barred and not subject to equitable tolling.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Wershe’s claims were indeed time-barred under the applicable statutes of limitations and that he was not entitled to equitable tolling. The court found that Wershe had constructive knowledge of the filing deadlines, did not diligently pursue his claims, and that the defendants would be prejudiced by the delay. Additionally, the court ruled that the district court did not err in dismissing the complaints with prejudice or in its handling of materials outside the pleadings. View "Wershe v. City of Detroit" on Justia Law

In late 2019, Verizon Wireless identified a coverage gap in Berlin Township, Ohio, and partnered with TowerCo to construct a cell tower to address this issue. TowerCo secured a lease with the local school district to build the tower on school property. Initially, TowerCo notified local residents as required by zoning regulations but later claimed immunity from these regulations under Ohio's "Brownfield immunity" doctrine, arguing that the project served a public purpose. Despite this claim, the Township insisted on compliance with local zoning laws, leading to a dispute.The Township filed a complaint in the Delaware County Common Pleas Court seeking a declaratory judgment and an injunction to halt the tower's construction. TowerCo counterclaimed under the Telecommunications Act (TCA) and removed the case to federal court. After negotiations failed, TowerCo filed a separate federal lawsuit asserting TCA violations and sought a preliminary injunction to continue construction. The district court granted the preliminary injunction, finding that the Township's actions likely violated the TCA by effectively prohibiting wireless services.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's order. The appellate court held that the Township's filing of a state court lawsuit did not constitute a "final action" under the TCA, which is necessary to trigger the Act's remedies. Additionally, TowerCo failed to file its federal TCA claims within the 30-day statutory deadline after the Township's state court filing. The court concluded that TowerCo's claims were not ripe and were time-barred, and thus, TowerCo could not show a likelihood of success on the merits. Consequently, the preliminary injunction was reversed, and the case was remanded for further proceedings. View "TowerCo 2013, LLC v. Berlin Township Board of Trustees" on Justia Law

In January 2019, Detective Lori Russ searched Connie Reguli’s private Facebook records, allegedly due to Russ’s dislike of Reguli’s criticism of the police. Reguli discovered the search a year later while preparing for her criminal trial but did not sue at that time. In July 2022, during her sentencing, Russ seemed to admit that Reguli’s speech motivated the search. Reguli then filed a First Amendment retaliation claim against Russ and her employer in November 2022 under 42 U.S.C. § 1983.The United States District Court for the Middle District of Tennessee dismissed Reguli’s claim as untimely, reasoning that the claim accrued when Reguli learned of the search in January 2020, not when she learned of Russ’s motivation in July 2022. The court applied Tennessee’s one-year statute of limitations for § 1983 claims, concluding that Reguli’s lawsuit was filed too late.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that Reguli’s First Amendment retaliation claim accrued when she discovered the search in January 2020, as she knew of the injury and its cause at that time. The court rejected Reguli’s argument that the claim accrued only when she learned of Russ’s retaliatory motive, stating that the statute of limitations begins when the plaintiff knows or should know of the injury, not necessarily the motive behind it. The court also noted that Reguli did not renew her tolling argument on appeal, thus forfeiting it. View "Reguli v. Russ" on Justia Law

Marc Susselman received a traffic ticket from a Washtenaw County Sheriff’s deputy for failing to yield to a police cruiser with flashing lights. This ticket was later dismissed, but Susselman received another citation for failing to obey a police officer directing traffic. The Michigan circuit court ultimately dismissed the second ticket as well. Susselman then filed a federal lawsuit asserting constitutional and state law claims against Washtenaw County, the Washtenaw County Sheriff’s Office, the sheriff’s deputy, and Superior Township, Michigan.The United States District Court for the Eastern District of Michigan granted the defendants' motions to dismiss all claims. Susselman appealed the decision. The district court had found that the Washtenaw County Sheriff’s Office could not be sued under 42 U.S.C. § 1983 and that Susselman had waived certain state-law claims. The court also dismissed Susselman’s federal claims, including First Amendment retaliation and Fourteenth Amendment malicious prosecution, as well as state-law claims for malicious prosecution and intentional infliction of emotional distress.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that Susselman failed to plausibly allege a constitutional violation or behavior by the deputy that would support his claims. Specifically, the court found that the issuance of the second ticket did not constitute a violation of substantive due process or First Amendment rights. Additionally, the court determined that Susselman did not establish a civil conspiracy or meet the requirements for his state-law claims. The court also concluded that Susselman did not identify any municipal policy or custom that resulted in a constitutional violation, thus dismissing his claims against Washtenaw County and Superior Township. View "Susselman v. Washtenaw County Sheriff's Office" on Justia Law

Vista-Pro Automotive, LLC, a Nashville-based auto-parts corporation, entered bankruptcy proceedings in 2014. In February 2015, Vista-Pro initiated an adversary proceeding against Coney Island Auto Parts Unlimited, Inc., a New York corporation, to recover approximately $50,000 in unpaid invoices. Vista-Pro mailed a summons and complaint to Coney Island's Brooklyn address, but without addressing it to any specific individual. Coney Island did not respond, leading the bankruptcy court to enter a default judgment against it in May 2015. In April 2016, the trustee appointed for Vista-Pro sent a demand letter to Coney Island's CEO, Daniel Beyda, to satisfy the default judgment. Coney Island acknowledged receipt of this letter.Coney Island later moved to vacate the default judgment in October 2021, arguing that the judgment was void due to improper service, as the summons and complaint were not addressed to an individual as required by Bankruptcy Rule 7004(b)(3). The Southern District of New York bankruptcy court denied the motion, instructing Coney Island to seek relief from the Middle District of Tennessee court. In July 2022, Coney Island filed a motion under Federal Rule of Civil Procedure 60(b)(4) to vacate the default judgment, claiming it was void. Both the bankruptcy court and the district court denied the motion as untimely, noting Coney Island's unreasonable delay in filing the motion.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the lower courts' decisions. The court held that Rule 60(b)(4) motions, which seek to vacate void judgments, must be filed within a "reasonable time" as stipulated by Rule 60(c)(1). The court found that Coney Island's delay in filing the motion was unreasonable, given that it had actual notice of the default judgment by April 2016 but did not move to vacate it until July 2022. The court emphasized that its precedent requires adherence to the reasonable-time limitation for Rule 60(b)(4) motions, even if the judgment is alleged to be void. View "In re Vista-Pro Automotive, LLC" on Justia Law

The case involves Mike Govender Hatchet, a Sierra Leone citizen who sought to adjust his immigration status to that of a lawful permanent resident in the United States. Hatchet applied for discretionary relief multiple times, but the United States Citizenship and Immigration Services (USCIS) denied each application, citing facts that rendered Hatchet ineligible for discretionary relief. Hatchet challenged the agency's actions in federal district court, arguing that the agency relied on facts clearly at odds with the record.The case was initially heard in the United States District Court for the Middle District of Tennessee. The district court dismissed Hatchet's case for lack of subject-matter jurisdiction, agreeing with the defendants' argument that the Supreme Court's recent decision in Patel demonstrated that Hatchet's claims were not subject to judicial review due to a jurisdiction-stripping statute.The case was then appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court's dismissal for lack of subject-matter jurisdiction. The court held that the district court lacked jurisdiction to review the factual findings of USCIS, and because Hatchet's arguments were entirely fact-bound, the court agreed that the district court properly dismissed the case for lack of subject-matter jurisdiction. The court's decision was based on the Supreme Court's recent decision in Patel, which held that federal courts are without jurisdiction to review both discretionary and non-discretionary judgments related to the granting of relief, including factual findings. View "Hatchet v. Andrade" on Justia Law

In 1987, Michael Kitchen, a seventeen-year-old, was sentenced to forty-two to sixty years in prison by a Michigan state court for his involvement in a home invasion. Under Michigan law, Kitchen is not eligible for parole until he completes his minimum sentence, which means he will not be considered for parole until he is nearly sixty. Kitchen filed a pro se § 1983 suit challenging the statute against Michigan’s governor, the Department of Corrections Director, and the chair of the Parole Board. He alleges that Michigan’s parole statute violates his Eighth Amendment rights because it effectively keeps him in prison for life without parole. The district court sided with Kitchen.The district court agreed with Kitchen and ruled against Defendants in an opinion and order on August 16, 2019. The court concluded that, despite the “legal and factual support” for Defendants’ position, “Kitchen is not required to bring his federal constitutional claims via a petition for a writ of habeas corpus,” and he could pursue them under § 1983. The district court thus rejected Defendants’ Heck argument. The Heck issue was not litigated any further.The United States Court of Appeals for the Sixth Circuit disagreed with the district court's decision. The court held that Kitchen's claim, if successful, would necessarily imply the invalidity of his sentence. Therefore, his claim must be brought through habeas corpus, not § 1983. The court reversed the district court's decision and remanded the case for further proceedings. View "Kitchen v. Whitmer" on Justia Law

The case involves the Tennessee Conference of the National Association for the Advancement of Colored People (NAACP) challenging a state policy that requires some convicted felons to submit additional documentation to confirm their eligibility to vote. The NAACP argued that this policy violated the National Voter Registration Act (NVRA). A district court agreed with the NAACP and permanently enjoined the policy in the middle of the 2024 election cycle. Tennessee's Secretary of State and Coordinator of Elections appealed this decision and sought a stay of the injunction pending appeal.The district court's decision was based on the finding that the NAACP had standing to challenge the policy and that the policy violated the NVRA. The court held that the policy was unnecessary for determining the eligibility of those with felony convictions as the state had other information at its disposal to make that decision.The United States Court of Appeals for the Sixth Circuit granted the stay for two reasons. First, the injunction triggered the Supreme Court’s “Purcell principle,” which instructs federal courts not to disrupt state election rules close to an election. Second, the court found that the NAACP likely did not present enough evidence to prove its standing to challenge the Documentation Policy. The court concluded that the NAACP's claim that the policy forced it to divert its resources to help those convicted of felonies track down the records they need to register was not supported by specific facts. View "Tennessee Conference of the NAACP v. Lee" on Justia Law

This case involves a catastrophic wildfire that occurred in 2016 in the Great Smoky Mountains National Park in Eastern Tennessee. The fire spread into Gatlinburg and Sevier County, resulting in the destruction of over 2,500 structures and the death of 14 people. The appellant insurance companies paid claims to policy holders and then filed claims under the Federal Tort Claims Act (FTCA) against the National Park Service (NPS), alleging negligence for failure to follow multiple mandatory fire-management protocols and for the failure to issue mandatory warnings to the public.The government moved to dismiss the case for lack of subject-matter jurisdiction, arguing that it was immune from suit under the discretionary-function exception to the FTCA. The district court granted the motion on all three claims relating to fire-management protocols, but denied the motion on claims relating to the duty to warn. The insurance companies appealed, and the government cross-appealed.The United States Court of Appeals for the Sixth Circuit reversed the district court's order granting the government's motion to dismiss the insurance companies' incident-command claim. The court affirmed the district court's dismissal of the fire-monitoring claim and the Wildland Fire Decision Support System (WFDSS) claim as part of the discretionary fire-suppression decision-making process. The court also affirmed the district court's denial of the government's facial challenge to the insurance companies' duty-to-warn claims, and remanded these claims for further proceedings. View "American Reliable Insurance Co. v. United States" on Justia Law