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

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

The plaintiff, Ilya Kovalchuk, was driving his vehicle when off-duty police officer Matthew Ward began driving erratically behind him, ordered him to pull over, and held Kovalchuk at gunpoint without any justification. Kovalchuk filed a lawsuit against Ward and the City of Decherd, Tennessee, alleging that Ward violated his Fourth Amendment rights and that the City’s failure to investigate Ward’s background before hiring him led to Kovalchuk’s injuries. The district court dismissed the claims against the City, finding that Kovalchuk failed to adequately plead allegations supporting municipal liability.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court determined that in order to survive a motion to dismiss, a plaintiff must allege facts that, if accepted as true, are sufficient to state a claim to relief that is plausible on its face. The court found that Kovalchuk did not plausibly allege that the City of Decherd was deliberately indifferent to a known or obvious consequence of its decision to hire Ward. According to the court, Kovalchuk's allegations of "issues," "concerns about [Ward’s] demeanor and professionalism," and his "fail[ure] to complete [a] training program" were insufficient to establish a causal link between Ward's hiring and Kovalchuk's injury. The court further stated that a plaintiff cannot use discovery to bridge the gap between a deficient pleading and the possibility that a claim might survive upon further investigation. Therefore, the court affirmed the district court's dismissal of Kovalchuk's claims against the City of Decherd. View "Kovalchuk v. City of Decherd" on Justia Law

In this consolidated appeal involving two cases from the Western District of Michigan and the Southern District of Ohio, the United States Court of Appeals for the Sixth Circuit ruled on how pizza-delivery drivers should be reimbursed for the cost of using their vehicles for work. The main dispute lay in the reimbursement method: the Michigan court sided with the drivers, stating they should be reimbursed based on a mileage rate published by the IRS, while the Ohio court agreed with the employers, stating a "reasonable approximation" of the drivers' costs suffices. The Sixth Circuit disagreed with both courts and vacated their decisions.The central issue involved the Fair Labor Standards Act (FLSA) requirement that employers pay each employee at least a minimum wage. The court found that if an employer required a minimum-wage employee to provide his own "tools" for work (in this case, their own vehicles), the employer must reimburse them for 100% of the cost of doing so. The court emphasized that the FLSA mandates that each employee be paid at least the specified minimum wage, not a "reasonable approximation".The court also disagreed with the plaintiffs’ argument that they should be reimbursed using the IRS's standard-mileage rate for business deductions, as it is a nationwide average and does not consider the individual costs of each driver. The court emphasized that the statute entitles a minimum-wage employee to reimbursement of actual costs incurred on the employer's behalf, neither more nor less. The case was remanded back to the lower courts for further proceedings. View "Parker v. Battle Creek Pizza, Inc." on Justia Law

In the case before the United States Court of Appeals for the Sixth Circuit, State Farm Mutual Automobile Insurance Company ("State Farm") brought a lawsuit against Michael Angelo, alleging violations of the Racketeer Influenced and Corrupt Organizations Act ("RICO"). The lawsuit claimed that Angelo submitted fraudulent bills to the insurance company. Angelo later filed a separate action against State Farm under the False Claims Act ("FCA"), alleging that the insurance company wrongfully avoided paying medical benefits. This action was unknown to State Farm at the time because FCA complaints are required to be filed under seal.The two parties entered into a settlement agreement in February 2021, resolving the RICO action. As part of the agreement, Angelo agreed to take all necessary steps to dismiss certain claims against State Farm. After the settlement agreement was signed, the FCA complaint was unsealed and served on State Farm. State Farm then sought to enforce the settlement agreement, arguing that it required Angelo to dismiss the FCA action as well.Angelo argued that the settlement agreement did not apply to the FCA action because the FCA claims were unrelated to the settled RICO claims. However, the district court disagreed and ordered Angelo to seek the government's consent to dismiss his FCA claims against State Farm. Angelo appealed this decision, claiming it violated his First Amendment rights and the FCA.The Court of Appeals affirmed the district court's decision, stating that the settlement agreement clearly encompassed the FCA action. The court also held that the district court had not erred in requiring Angelo to seek the government's consent to dismiss his FCA claims. Angelo's First Amendment claim was deemed forfeited as it was raised for the first time in a motion for reconsideration and was thus untimely. View "State Farm Mutual Automobile Insurance Co. v. Angelo" on Justia Law

In this case, DeShawn Anderson-Santos, a juvenile detainee at the Kent County Juvenile Detention Center, claimed he suffered a head injury after being pushed by corrections officer Derek Leshan. Anderson-Santos filed a lawsuit against Leshan under 42 U.S.C. § 1983, the Fourteenth Amendment, and the Eighth Amendment, alleging the use of excessive force. Leshan sought summary judgment arguing qualified immunity. The district court denied Leshan’s motion, finding that there was a genuine dispute of material fact as to whether Leshan had used excessive force, thus violating the Eighth Amendment. The court also found that Leshan was not entitled to qualified immunity at the summary judgment stage. Leshan appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit dismissed the appeal for lack of jurisdiction. The court noted that while denials of summary judgment are not typically appealable on an interlocutory basis, an exception exists for denials of claims of qualified immunity if the appeal turns on a legal issue. However, the court found that Leshan's appeal ultimately turned on questions of fact rather than an issue of law, divesting the court of jurisdiction. The court explained that a defendant seeking to challenge a denial of qualified immunity based on a genuine dispute of material fact may invoke the court's jurisdiction by conceding the plaintiff's version of the facts. However, the court determined that Leshan did not truly concede Anderson-Santos' version of the facts, thus the court lacked jurisdiction to hear the appeal. View "Anderson-Santos v. Kent County" on Justia Law

In a case before the United States Court of Appeals for the Sixth Circuit, Premier Dealer Services, a developer and administrator of automobile dealers’ aftermarket products, sued Allegiance Administrators for infringing its copyright. The issue stemmed from Premier's creation of a Lifetime Powertrain Loyalty Program, which included a loyalty certificate that set out the program's terms and conditions. Premier had registered this certificate for copyright protection. When Allegiance started working with a former Premier client, it used Premier’s Lifetime Powertrain Loyalty Program certificates in its own plan, with minor modifications in the contact information.In the lawsuit, the district court ruled that Allegiance had infringed Premier’s copyright, ordered Allegiance to give up any profits from using the certificates, and awarded Premier attorney’s fees. On appeal, the Sixth Circuit affirmed the decision of the lower court.The appellate court held that Premier's certificate was "original" and thus protected by copyright. The court clarified that originality in copyright law has a low threshold, requiring only that the author independently created a work with some minimal degree of creativity. The court rejected Allegiance's argument that the certificates were scenes a faire—stock or standard phrases that necessarily follow from a common theme or setting, which are not protectable by copyright. The court found that Allegiance had not provided sufficient evidence that industry standards or other external constraints dictated the content of the certificates.Regarding the disgorgement of profits, the court agreed with the lower court's calculations. It noted that Premier had successfully shown a reasonable relationship between Allegiance’s infringement and its gross revenues. The burden then shifted to Allegiance to demonstrate which part of its gross revenues did not result from the infringement, but Allegiance failed to fulfill this burden.Finally, the court upheld the award of attorney’s fees to Premier, finding that the lower court did not abuse its discretion in characterizing Allegiance's arguments as unreasonable and contrary to settled law. View "Premier Dealer Services, Inc. v. Allegiance Administrators, LLC" on Justia Law

In this case heard by the United States Court of Appeals for the Sixth Circuit, the plaintiff, Marketing Displays International (MDI), sued the defendant, Brianna Shaw, for allegedly violating her one-year non-compete agreement when she left MDI and began working for another company. The district court granted a preliminary injunction, preventing Shaw from working for her new employer for one year. Shaw appealed this decision in January 2023. However, due to several deadline extensions requested by both parties, the briefing did not finish until January 2024. By that time, the one-year period of the injunction had already expired, rendering the appeal moot.Shaw argued that the appeal was not moot as a ruling would impact her ability to recover any damages, including reputational harm caused by the injunction, and MDI's ability to recover attorney fees. The court disagreed, stating that Shaw could not collect damages until a final judgment is in her favor, and MDI's right to attorney fees did not depend on the validity of the preliminary injunction.Shaw also requested the court to vacate the moot portion of the preliminary injunction. However, the court refused, stating that the injunction would not have any preclusive effect on future litigation and that Shaw contributed to the appeal's mootness by requesting deadline extensions.Therefore, the appeal was dismissed as moot, and the case was remanded back to the lower court for further proceedings. View "Marketing Displays International v. Shaw" on Justia Law

In a multi-district litigation involving diabetes drug saxagliptin, the plaintiffs claimed that the drug caused their heart failure. They presented a single expert to show the drug could cause heart failure. After a Daubert hearing and expert motions, the United States Court of Appeals for the Sixth Circuit found that the expert's testimony was unreliable due to methodological flaws and therefore excluded it. Subsequently, the district court granted summary judgment for the defendants, rejecting the plaintiffs' claim that other evidence created a genuine issue of material fact. The court also refused the plaintiffs' request for ninety days to find a replacement expert. On appeal, the plaintiffs challenged the district court's exclusion of their expert, its grant of summary judgment, and its refusal to give them more time to find another expert witness. The Court of Appeals affirmed the district court's decisions, stating that the plaintiffs' claims lacked merit. The court found that the expert's reliance on one study to the exclusion of all others was unreliable, that his use of animal data was unreliable due to his admitted lack of qualifications to analyze such studies, and that he did not reliably apply the Bradford Hill criteria - a scientific framework used to analyze whether an association between two variables is causal. The court also found that all jurisdictions require expert testimony to show general causation in complex medical cases such as this one. As the plaintiffs failed to identify a reliable general causation expert, the court granted summary judgment for the defendants. The court also found no good cause to grant the plaintiffs more time to find a replacement expert. View "In re Onglyza (Saxagliptin) and Kombiglyze (Saxagliptin and Metformin) Products Liability Litigation" on Justia Law

In this case, Autumn Wind Lending, LLC (Autumn Wind) had lent money to Insight Terminal Solutions, LLC (Insight) under an agreement that Insight would not incur any further debt without Autumn Wind's consent. However, Insight defaulted on the loan and filed for bankruptcy, during which it was revealed that it had taken on additional debt from other parties, including John J. Siegel and three family enterprises. Autumn Wind, which had become the parent company of Insight, then filed a lawsuit against these parties, alleging fraud and tortious interference. The United States Court of Appeals for the Sixth Circuit was asked to decide whether the doctrine of res judicata, which bars relitigation of a claim that has been adjudicated, prevented Autumn Wind from bringing these claims. The court held that the doctrine of res judicata did not bar Autumn Wind from bringing its claims. The court reasoned that the claims had not been "actually litigated" because they were dismissed by stipulation in the bankruptcy court, not decided on the merits. Furthermore, Autumn Wind could not have litigated these claims in the bankruptcy court because it was not a party to the bankruptcy proceedings. The court therefore reversed the district court's dismissal of Autumn Wind's claims and remanded the case for further proceedings. View "Autumn Wind Lending, LLC v. Siegel" on Justia Law