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

The case involves Ariel Schlosser, who was hired by VRHabilis, LLC (VRH) to perform unexploded ordnance (UXO) remediation. Schlosser, the only female diver, faced several incidents of alleged discrimination and harassment. She was singled out for a knot-tying test, prohibited from diving and driving the company vehicle, and subjected to verbal abuse by her supervisor, Tyler Sanders, and co-worker, Aaron Brouse. Schlosser reported the harassment, but VRH's response was inadequate, leading her to resign after ten weeks.The United States District Court for the Eastern District of Tennessee denied VRH's motion for summary judgment, allowing the case to proceed to trial. After a four-day trial and three days of deliberations, the jury found that Schlosser was subjected to a hostile work environment based on her sex or gender, in violation of Title VII of the Civil Rights Act of 1964. The jury awarded Schlosser $58,170 in back pay. VRH filed a renewed motion for judgment as a matter of law, arguing that the evidence did not support the jury's verdict. The district court denied this motion, holding that the jury could reasonably conclude that Schlosser experienced severe and pervasive harassment based on her gender.The United States Court of Appeals for the Sixth Circuit reviewed the district court's denial of VRH's renewed motion for judgment as a matter of law de novo. The court affirmed the district court's judgment, finding that the jury could reasonably determine that Schlosser was subjected to a hostile work environment based on her sex or gender. The court held that the harassment was severe and pervasive, and that VRH was liable for the actions of Schlosser's supervisor and co-worker. The court emphasized the substantial deference owed to the jury's verdict and concluded that VRH had not overcome this deference. View "Schlosser v. VRHabilis, LLC" on Justia Law

Aimee Sturgill, a registered nurse and devout Christian, objected to the American Red Cross's COVID-19 vaccination mandate, citing her religious beliefs. She requested a religious exemption, explaining that her faith required her to treat her body as a temple and avoid defiling it with the vaccine, which she believed could cause harm due to her blood clotting disorder. The Red Cross denied her request, stating that her objections were medically, not religiously, based and terminated her employment.The United States District Court for the Eastern District of Michigan dismissed Sturgill's complaint under Federal Rule of Civil Procedure 12(b)(6). The court held that she did not plausibly allege a prima facie case for a failure-to-accommodate claim under Title VII of the Civil Rights Act of 1964. The court also concluded that Sturgill did not set forth a separate disparate-treatment claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred by requiring Sturgill to establish a prima facie case at the pleading stage, which is not necessary under the plausibility standard set by Twombly and Iqbal. The appellate court found that Sturgill's complaint plausibly alleged that her refusal to take the COVID-19 vaccine was an aspect of her religious observance or belief. However, the court agreed with the district court that Sturgill's complaint did not set forth a standalone disparate-treatment claim. Consequently, the Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. View "Sturgill v. American Red Cross" on Justia Law

Thomas Merck applied for an entry-level position at Walmart and was given a conditional job offer pending a background check. Merck failed to disclose an old misdemeanor conviction, which was discovered during the background check. Walmart, through a third-party vendor, provided Merck with an incomplete version of the report, which indicated he was "not competitive" for the job. Walmart then revoked the job offer. Merck claimed that Walmart violated the Fair Credit Reporting Act by not providing him with the full consumer report before taking adverse action.The United States District Court for the Southern District of Ohio initially denied Walmart's motion to dismiss, finding that Merck had standing based on a procedural violation of the Act. However, after the Supreme Court's decision in TransUnion LLC v. Ramirez, which clarified the requirements for standing under the Fair Credit Reporting Act, Walmart renewed its motion for summary judgment. The district court granted the motion, concluding that Merck had not demonstrated a concrete injury as required by TransUnion.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Merck failed to show he suffered adverse effects from the denial of the full consumer report. Specifically, Merck did not provide evidence that he could have used the withheld information to his benefit, such as changing the outcome of his job application or affecting his subsequent job search. The court also rejected Merck's analogy to procedural due process claims and traditional common-law harms, finding that the statutory duty under the Fair Credit Reporting Act did not closely resemble these traditional harms. Therefore, Merck did not have constitutional standing to sue Walmart. View "Merck v. Walmart, Inc." on Justia Law

Next Century Rebar, LLC (NCR) worked on a project in Detroit, Michigan, within the jurisdiction of Local Union Number 25 (Local 25). Due to a shortage of Local 25 iron workers, NCR hired workers from out-of-state unions, Local 416 and Local 846. NCR made benefits contributions to the funds associated with these out-of-state unions. In 2021, Local 25 Funds conducted an audit and found that NCR had not made contributions to the Local 25 Funds for these out-of-state employees. NCR contested this, arguing that it had already made contributions to the out-of-state funds.The Local 25 Funds filed a lawsuit under 29 U.S.C. § 1145, seeking unpaid contributions. The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Local 25 Funds, awarding them $1,787,300.75 in unpaid contributions, $143,075.41 in interest, and $288,598.80 in liquidated damages. The court also awarded $18,233.15 in costs and $99,812.25 in attorney fees. NCR appealed, arguing that the district court applied the wrong summary-judgment standard, improperly granted summary judgment despite genuine disputes of material fact, and abused its discretion by not awarding a setoff for contributions made to out-of-state funds.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Local 25 CBA required contributions based on the specific employee’s gross earnings for the vacation fund and base wages for the pension fund. However, it was unclear whether the audit used the correct wage rates. The court also found that the Local 25 Funds' request for contributions violated the International Agreement’s prohibition on double payments. Consequently, the court affirmed the district court’s decision in part, reversed it in part, and remanded the case for further proceedings. View "Trustees of Iron Workers Defined Contribution Pension Fund v. Next Century Rebar, LLC" on Justia Law

In 1974, Regina Andrews was found murdered, and her husband, Isaiah Andrews, was convicted of the crime based on circumstantial evidence. After nearly 46 years in prison, Isaiah was granted a new trial in 2020 when it was discovered that exculpatory evidence had been withheld. A new jury acquitted him in 2021. Subsequently, Isaiah filed a § 1983 lawsuit against the City of Cleveland and several officers, alleging violations of his Fourteenth Amendment rights due to the suppression of exculpatory evidence.The United States District Court for the Northern District of Ohio dismissed Isaiah's claims against the estates of the deceased officers, William Hubbard and Ernest Rowell, citing that the claims were filed too late under Ohio law. The court also granted summary judgment in favor of the City of Cleveland, concluding that the police did not withhold exculpatory evidence from the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of claims against the estates of Hubbard and Rowell, agreeing that Isaiah's claims were untimely under Ohio law. However, the court reversed the summary judgment in favor of the City of Cleveland. The appellate court found that there was a material dispute of fact regarding whether the police had withheld a crucial page of a police report linking another suspect to the crime scene. The court remanded the case to the district court to determine whether a City policy caused the alleged Brady violation. View "Estate of Andrews v. City of Cleveland" on Justia Law

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