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

The defendant, while on supervised release following a federal conviction for being a felon in possession of a firearm, was arrested in May 2023 for new state charges involving drug trafficking, possession of marijuana and drug paraphernalia, and being a felon in possession of a handgun. These events occurred after violations that led to his second supervised release revocation but before the hearing for those violations, and were not discovered by the federal probation office until several months later. Upon learning of the May 2023 incident, after the defendant had completed his sentence and was again on supervised release, the probation office initiated the proceedings at issue, seeking a third revocation based on the new conduct.The United States District Court for the Eastern District of Kentucky held a hearing to determine if the defendant could knowingly and voluntarily waive his right to counsel in the revocation proceeding, ultimately allowing him to represent himself. After a subsequent hearing, the district court found violations of supervised release, classified the new conduct as a Grade A violation, and imposed a 24-month term of imprisonment, the statutory maximum. The defendant timely appealed, challenging the validity of his waiver of counsel, the sentencing procedure, and the constitutionality of his underlying conviction.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the right to counsel in a supervised release revocation is not derived from the Sixth Amendment but is governed by statutory and due process considerations. The court reviewed the waiver of counsel for abuse of discretion and found the district court’s inquiry sufficient under the totality of the circumstances. The court also found no procedural error in sentencing, concluding that the district court did not improperly rely on prohibited factors. Finally, the court declined to consider the challenge to the underlying conviction, holding that such arguments must be raised on direct appeal or collateral review. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Spence" on Justia Law

Two police officers responded to a report of an armed suspect in a Cleveland boarding house. While searching the darkened building, the officers encountered the suspect, leading to a confrontation and retreat down the stairs. One officer, Gannon, fired his weapon twice; the first, intentional shot struck his fellow officer, Kilnapp, causing significant injury. The officers did not identify themselves as police during the incident, and the body camera footage did not clearly depict critical moments. Both sides disputed details such as whether the suspect fired first, but agreed that Gannon’s first shot, meant to stop the suspect, hit Kilnapp as she followed behind him.Kilnapp sued Gannon, the City of Cleveland, and its Chief of Police, alleging excessive force under both the Fourth and Fourteenth Amendments. Gannon sought qualified immunity and dismissal, arguing his actions did not violate clearly established rights. The United States District Court for the Northern District of Ohio denied his motion to dismiss and later his motion for summary judgment on qualified immunity grounds. The Sixth Circuit previously affirmed the denial of the motion to dismiss, but Gannon continued to challenge the denial of summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of summary judgment de novo. The court held that when an officer intentionally fires a weapon in circumstances objectively manifesting an intent to restrain, any person struck is seized under the Fourth Amendment, regardless of whether they were the officer’s specific intended target. However, because the Supreme Court’s decision in Torres v. Madrid (2021) clarified this principle after Kilnapp’s shooting, the law was not clearly established at the time. The Sixth Circuit vacated the district court’s decision and remanded with instructions to grant Gannon qualified immunity on the Fourth Amendment claim and for further proceedings on the Fourteenth Amendment claim. View "Kilnapp v. City of Cleveland" on Justia Law

A woman was murdered by her neighbor, who had a documented history of violence and mental illness. Over the two years preceding her death, the Sheriff’s Office in the relevant county received multiple reports about the neighbor’s threatening behavior, particularly toward women, but allegedly failed to act appropriately. The decedent’s estate claimed that the Sheriff’s Office systematically provided inferior protective services in response to threats against women compared to men, citing examples involving both the decedent and other women who reported threats. The estate asserted claims under the Equal Protection Clause and Michigan’s Elliott-Larsen Civil Rights Act.The United States District Court for the Western District of Michigan dismissed the federal claims for lack of standing and for failure to state a claim, and declined to exercise supplemental jurisdiction over the state-law claims. The estate appealed, challenging only the dismissal of its federal equal protection claims.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the estate lacked standing to bring the federal equal protection claims because the complaint did not allege that the decedent herself was personally denied equal protection by the Sheriff’s Office. Instead, the complaint described discriminatory treatment experienced by other women. The court explained that equal protection claims must be based on the plaintiff’s own legal rights, not those of third parties, and the estate did not qualify for the limited exception allowing third-party standing. As a result, the court affirmed the district court’s dismissal of the complaint in its entirety. View "Henry v. Blank" on Justia Law

Joshua Steeb was severely injured after intervening to save his friend, Teresa Fitzgerald, from a violent dog attack at the home of Linda Motter, Fitzgerald’s relative. The dog, known for its aggressive history and previously quarantined by local authorities, was reported to animal control for removal. Officer Mike Ehart, aware of the dog’s past behavior, arrived on the scene but instead of personally handling the dog, he instructed Fitzgerald to retrieve and secure the animal in his truck. Despite Fitzgerald’s apprehension and knowledge of the dog’s dangerous tendencies, she attempted the task and was attacked. Steeb’s attempt to rescue her resulted in the dog mauling him, causing permanent injuries.The United States District Court for the Western District of Michigan reviewed Steeb’s claims under 42 U.S.C. § 1983, which were based on the “state-created-danger” theory of substantive due process. Steeb argued that Officer Ehart’s conduct created or increased the risk that led to the attack and that the City of Battle Creek failed to properly train and equip Ehart. The district court dismissed all federal claims, finding that Steeb had not alleged a plausible constitutional violation. As a result, the court declined to exercise jurisdiction over the related state law claims, dismissing them without prejudice.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The appellate court held that Steeb failed to plausibly allege that Officer Ehart took an “affirmative act” sufficient to invoke the state-created-danger doctrine, primarily because Fitzgerald voluntarily assumed the risk of handling the dangerous dog. Without a constitutional violation, the municipal liability claim against the City of Battle Creek also failed. The appellate court thus affirmed the dismissal of Steeb’s claims. View "Steeb v. Ehart" on Justia Law

Michael Victor was detained overnight in an Otsego County, Michigan jail after being arrested for disorderly conduct and resisting an officer. Victor, who has epilepsy, did not receive his prescribed anti-seizure medication while in custody, despite his mother delivering it to the jail and officers being informed of his medical needs. The jail’s procedures required officers to contact an on-call medical provider from Advanced Correctional Healthcare (ACH) before administering any medication. After his release the next morning, Victor suffered a seizure, resulting in significant injuries.The United States District Court for the Eastern District of Michigan heard Victor’s civil rights suit against ACH and Nurse Kimberly Reynolds. At trial, Victor presented evidence including testimony from officers and medical staff, but no one recalled making or receiving a call to ACH regarding his medication, and no records indicated any such contact. The jury found in favor of Reynolds but against ACH, awarding Victor economic, noneconomic, and punitive damages. ACH moved for judgment as a matter of law or a new trial, arguing insufficient evidence that any officer contacted ACH. The district court granted ACH’s motions, holding there was not enough evidence for a reasonable jury to find that contact occurred, and also denied Victor’s request for sanctions related to alleged discovery violations.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Victor had presented sufficient evidence to allow a reasonable jury to find that an officer had contacted ACH about his medication needs. The court held that the absence of any records and the lack of recollection from all involved witnesses meant Victor had not met his burden. Testimony indicating intent to call, without corroboration, was not enough. The Sixth Circuit affirmed the district court’s judgment as a matter of law for ACH and found no abuse of discretion in denying sanctions. View "Victor v. Reynolds" on Justia Law

Louis Alford was stopped by Cannon County Sheriff’s Deputies outside Woodbury, Tennessee for minor traffic violations. During the stop, Deputy Deffendoll observed a syringe filled with clear liquid inside Alford’s truck. A subsequent search revealed additional empty syringes, powder in a baggie, paper with residue, empty baggies, prescription pills not belonging to either occupant, and digital scales. Alford was arrested and charged with three state drug offenses. He spent time in jail, and his parole was revoked, resulting in over a year in prison. The drug charges were later dismissed. Forensic analysis showed the powder contained methamphetamine, but other items either contained noncontrolled substances or were not tested.Alford filed suit in the United States District Court for the Middle District of Tennessee against Deputies Deffendoll and Smith, and Cannon County, asserting false arrest, malicious prosecution, and Monell liability under 42 U.S.C. § 1983. After discovery, the district court granted summary judgment to the defendants on the federal claims, finding no genuine issue of material fact as to Smith’s involvement, and that Deffendoll had probable cause for arrest and prosecution. The court also rejected the Monell claim, finding no underlying constitutional deprivation. Alford appealed only the federal claims.On review, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The court held that Smith was not personally involved in the arrest, and Deffendoll had probable cause to arrest and charge Alford for simple possession and possession of drug paraphernalia. The court applied the proper summary judgment and qualified immunity standards, and clarified that probable cause existed for the charges that led to Alford’s seizure. Without a constitutional violation, Alford’s Monell claim failed. The court affirmed summary judgment for all defendants. View "Alford v. Deffendoll" on Justia Law

Several female students at a public university alleged that the school violated Title IX by failing to offer varsity-level women’s teams in equestrian, field hockey, and lacrosse. Although the university provided club-level opportunities for these sports, the plaintiffs contended that this did not satisfy the school’s obligation to offer equal athletic opportunities. Over the previous decade, the percentage of female students and female varsity athletes at the university increased, but women still comprised a smaller share of varsity athletes than of the total student body. The university periodically surveyed students to assess interest and ability for new varsity teams and maintained a review committee to monitor athletic opportunities.The United States District Court for the Eastern District of Kentucky held a three-day bench trial, considering testimony from students, coaches, and university staff, as well as survey data regarding student interest and ability in the relevant sports. The district court found that while women were underrepresented relative to the student body, the plaintiffs failed to show there were enough female students with the requisite interest and ability to compete at the Division I varsity level in equestrian, field hockey, or lacrosse. The court concluded the university had sufficiently accommodated the athletic interests and abilities of its female students and denied relief to the plaintiffs.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s factual findings for clear error and its legal conclusions de novo. The appellate court held that the district court did not clearly err in finding insufficient interested and able female students to form viable varsity teams in the disputed sports. The court also upheld the exclusion of an expert witness who lacked relevant survey design expertise. The Sixth Circuit affirmed the judgment in favor of the university, holding that Title IX does not require the creation of new varsity teams in the absence of demonstrated unmet demand and ability. View "Niblock v. University of Kentucky" on Justia Law

Dustin Booth, who had a history of stable employment and no prior mental health issues, began exhibiting signs of severe mental illness in early 2022 after changes in his substance use. His erratic behavior escalated over several days, culminating in a violent incident at home and a lengthy standoff with police after he barricaded himself inside his house. Booth’s wife repeatedly sought police intervention, expressing concerns that he was a danger to himself and others, and noted his access to firearms. After attempts to calm Booth and persuade him to leave his house, he eventually left with a friend, taking a gun with him. Police stopped the vehicle, leading to a confrontation in which Booth brandished the firearm and was fatally shot by officers.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants on all federal claims. The district court held that the proposed accommodation under the Americans with Disabilities Act (ADA)—that officers should have used de-escalation techniques—was unreasonable due to the safety risks posed by Booth. The court further found that the officers’ actions during the traffic stop and subsequent use of force, including the deployment of a police dog and takedown maneuver, were reasonable under the Fourth Amendment. It also declined to exercise supplemental jurisdiction over the state-law claims.Upon review by the United States Court of Appeals for the Sixth Circuit, the appellate court affirmed the district court’s decision. The Sixth Circuit held that, as a matter of law, the ADA did not require officers to accommodate Booth’s disability in the face of objective safety risks. Additionally, the court found the officers had probable cause for a mental-health seizure and acted reasonably under the Fourth Amendment in both the stop and use of force. The judgment in favor of the defendants was affirmed. View "Booth v. Lazzara" on Justia Law

Nationwide Recovery, a towing company, held a permit with the City of Detroit to recover stolen vehicles, which provided significant economic benefits. In July 2017, the Detroit Police Department suspected that a Nationwide tow operator was colluding with car-theft gangs by bribing them for tips on stolen vehicle locations. These suspicions led to the immediate suspension of Nationwide’s towing permit without a hearing. Subsequent investigations uncovered evidence suggesting that a Nationwide driver communicated with, and likely paid, known car thieves for information, allowing for rapid recovery of stolen vehicles. Further audits revealed that Nationwide had routinely charged excessive fees beyond the amounts permitted by city rules.In response to the suspension, Nationwide and associated plaintiffs filed suit in the United States District Court for the Eastern District of Michigan, alleging a procedural due process violation under 42 U.S.C. § 1983. The district court initially found that the towing permit constituted a property interest and that the lack of a hearing deprived Nationwide of due process. However, after extensive discovery, the district court concluded that, based on after-acquired evidence, Nationwide’s conduct—including collusion with car thieves and fee overcharging—would have justified termination even if a hearing had occurred. Therefore, the court limited Nationwide’s damages to nominal damages and entered judgment for one dollar.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions de novo and for abuse of discretion. The Sixth Circuit affirmed, holding that although the City failed to provide procedural due process, the after-acquired evidence justified permit termination, and thus Nationwide was not entitled to compensatory damages. The court clarified that in procedural due process cases, post-termination evidence may be considered, and where termination would have occurred regardless of the process, only nominal damages are available. The judgment for nominal damages was affirmed. View "Nationwide Recovery, Inc. v. City of Detroit" on Justia Law

HRT Enterprises owned an 11.8-acre parcel adjacent to Detroit’s Coleman A. Young International Airport, with about 20 percent of the property falling within a regulated runway “visibility zone” that restricted development. Over time, the City of Detroit acquired other properties in a nearby area for airport compliance but did not purchase HRT’s. By late 2008, HRT’s property had become vacant and vandalized, and HRT alleged it could no longer use, lease, or sell the property due to City actions and regulatory restrictions.HRT first sued the City in Michigan state court in 2002, alleging inverse condemnation, but the jury found for the City; the Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied leave to appeal. In 2008, HRT sued in federal court, but the United States District Court for the Eastern District of Michigan dismissed the action without prejudice because HRT had not exhausted state remedies. HRT then filed a second state suit in 2009, which was dismissed on res judicata grounds; the Michigan Court of Appeals affirmed. HRT did not seek further review.In 2012, HRT filed the present action in federal court, alleging a de facto taking under 42 U.S.C. § 1983. The district court denied the City’s preclusion arguments, granted summary judgment to HRT on liability, and held that a taking had occurred, leaving the date for the jury. A first jury found the taking occurred in 2009 and awarded $4.25 million; the court ordered remittitur to $2 million, then a second jury, after a new trial, awarded $1.97 million.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings, holding that HRT’s claim was ripe, not barred by claim or issue preclusion, that the district court properly granted summary judgment on liability, and that its remittitur decision was not an abuse of discretion. View "HRT Enterprises v. City of Detroit" on Justia Law