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

Misty Coleman alleges that she fell and broke her ankle after slipping on a wet shower floor in a county jail. She pursued constitutional claims under 42 U.S.C. § 1983 and negligence claims under Ohio law against the county, corrections officers, and medical personnel. Coleman claimed that the slippery shower violated the Due Process Clause and that a county policy or custom was behind her poor medical care. She also questioned whether the county could invoke state-law immunity from her negligence claim at the pleading stage.The United States District Court for the Southern District of Ohio dismissed all claims against all parties. The court found that Coleman failed to allege a plausible constitutional violation regarding the slippery shower and did not connect the inadequate medical care to a county policy or custom. The court also held that Ohio law granted immunity to Hamilton County on the negligence claim. The court allowed Coleman to conduct limited discovery to identify unnamed officers and nurses, but her subsequent amended complaint was dismissed as it was filed outside the statute of limitations.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court's dismissal, holding that Coleman’s claims accrued on the date of her accident and that her amended complaint did not relate back to the original complaint under Federal Rule of Civil Procedure 15. The court also found that Coleman did not meet the requirements for equitable tolling, as she did not allege facts showing that she was intentionally misled or tricked into missing the deadline. The Sixth Circuit affirmed the district court's dismissal of Coleman’s complaint. View "Coleman v. Hamilton County Bd. of County Commissioners" on Justia Law

In 1995, Garr Keith Hardin and Jeffrey Clark were convicted of murdering Rhonda Sue Warford based on forensic evidence and witness testimonies. Robert Thurman, a forensic serologist, testified that a hair found at the crime scene was similar to Hardin’s hair. After over two decades in prison, DNA testing revealed that the hair did not belong to Hardin, leading a state court to vacate their convictions. Hardin and Clark then sued Thurman under 42 U.S.C. § 1983, alleging that he failed to disclose observation notes that suggested the hair might not have matched Hardin’s hair sample, violating his obligations under Brady v. Maryland.The United States District Court for the Western District of Kentucky denied Thurman’s qualified-immunity defense for Hardin’s Brady claim but granted summary judgment on other claims. The court found that a reasonable jury could determine that Thurman should have recognized the exculpatory value of his notes and that the notes were material to Hardin’s defense. The court also held that Thurman could not invoke qualified immunity because Hardin’s Brady rights were clearly established before 1992.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s decision in part and dismissed in part for lack of jurisdiction. The Sixth Circuit held that it lacked jurisdiction to review Thurman’s arguments that the notes were not exculpatory or material, as these were mixed questions of law and fact. However, the court rejected Thurman’s argument that the law in the mid-1990s did not clearly establish that Brady’s duty of disclosure applied to forensic scientists, affirming that such duties were clearly established and applicable to Thurman. View "Clark v. Louisville-Jefferson County Metro Government" on Justia Law

Plaintiffs David Moore and David Ermold sued Kim Davis, the clerk of Rowan County, Kentucky, under 42 U.S.C. § 1983 for refusing to issue them a marriage license, claiming it violated their constitutional right to marry. This refusal occurred after the Supreme Court's decision in Obergefell v. Hodges, which legalized same-sex marriage nationwide. Davis, citing her religious beliefs, stopped issuing all marriage licenses until the state provided her with an accommodation. Plaintiffs sought damages for the emotional distress caused by Davis's actions.The United States District Court for the Eastern District of Kentucky ruled in favor of the plaintiffs on liability, and a jury awarded them compensatory damages. Davis appealed, arguing she was entitled to qualified immunity, had defenses under the Free Exercise Clause and the Kentucky Religious Freedom Restoration Act (RFRA), and that the evidence of emotional distress was insufficient to support the jury's award.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that Davis was not entitled to qualified immunity because Obergefell clearly established the right to same-sex marriage, and Davis's actions violated that right. The court also rejected Davis's Free Exercise Clause defense, stating that the First Amendment does not protect state actions that violate constitutional rights. Additionally, the court found that Kentucky's RFRA did not apply in this case because the state was not a party to the lawsuit.The court further upheld the jury's award of damages, finding that the plaintiffs provided sufficient evidence of emotional distress. The court noted that the plaintiffs' detailed testimony about their emotional harm was corroborated and not merely conclusory. Davis's request for remittitur was not considered because it was raised for the first time in her reply brief. The Sixth Circuit thus affirmed the district court's judgment in favor of the plaintiffs. View "Ermold v. Davis" on Justia Law

In March 2020, Andrew Cooperrider, owner of Brewed, a coffee shop and bar in Lexington, Kentucky, criticized Governor Beshear’s COVID-19 policies on social media. In November 2020, the Kentucky Department of Alcoholic Beverage Control (DABC) suspended Brewed’s alcohol license, and officially revoked it in March 2022. Cooperrider filed a lawsuit against Governor Beshear, DABC officials, and other state officials, alleging First Amendment retaliation and due-process violations, claiming the license revocation was in retaliation for his critical speech.The United States District Court for the Eastern District of Kentucky dismissed the case, granting the defendants' motions to dismiss. The court found that most of Cooperrider’s claims were barred by absolute, qualified, and sovereign immunity. It also determined that Cooperrider’s remaining substantive-due-process claim did not meet the Rule 12(b)(6) pleading standard.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of most claims, agreeing that the defendants were protected by absolute, qualified, and sovereign immunity. However, the appellate court found that the district court improperly granted qualified immunity to Governor Beshear, Ray Perry, and Wesley Duke regarding Cooperrider’s First Amendment retaliation claim. The appellate court held that Cooperrider had plausibly alleged that the enforcement action against Brewed was motivated by his protected speech. Consequently, the court reversed the district court’s decision on this point and remanded the case for further proceedings on the First Amendment retaliation claim. View "Cooperrider v. Woods" on Justia Law

Lamont Heard, a Michigan prisoner, claimed that prison officials retaliated against him for his litigation activities by transferring him to a different housing unit. He sought to sue the officials under 42 U.S.C. § 1983 for allegedly violating his First Amendment rights. Heard was transferred on January 10, 2017, and filed a grievance the next day. After exhausting his administrative remedies, he filed a lawsuit on January 19, 2021, four years and nine days after the transfer.The United States District Court for the Eastern District of Michigan dismissed Heard's claim for failure to exhaust administrative remedies. Heard then exhausted his remedies and refiled his lawsuit. The district court dismissed the refiled claim as untimely, reasoning that Michigan's tolling provision, which pauses the statute of limitations while a claim is pending in court, conflicted with the Prison Litigation Reform Act (PLRA).The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Michigan's tolling provision does not conflict with the PLRA's exhaustion requirement. The PLRA requires prisoners to exhaust administrative remedies before filing a federal lawsuit but does not address tolling. The court emphasized that federal courts have historically borrowed state statutes of limitations and tolling provisions for § 1983 suits. The court found that Michigan's tolling rule, which pauses the statute of limitations during a prior suit, is consistent with the PLRA and does not undermine its purposes. Consequently, the Sixth Circuit reversed the district court's judgment, allowing Heard's claim to proceed. View "Heard v. Strange" on Justia Law

Glorianna Moore was stopped by Officer Brian Wilson for speeding in Pontiac, Michigan. When Moore refused to show her license and moved her hands towards the center console, Wilson reached into her car, grabbed her arm, and ordered her to shut off the car. Moore resisted by screaming and twisting her body. Wilson restrained her by holding her arm and head until backup arrived. Moore was subsequently handcuffed and placed in Wilson's patrol car. Although an initial test indicated the presence of cocaine in Moore's car, further testing revealed it was not cocaine, leading to the dismissal of all charges against her.Moore filed a § 1983 action against Wilson and other officers, alleging excessive force in violation of her Fourth Amendment rights. The United States District Court for the Eastern District of Michigan granted summary judgment to all defendants except Wilson, who appealed the denial of his motion for summary judgment based on qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Officer Wilson did not violate clearly established Fourth Amendment principles. The court reasoned that Wilson's actions were reasonable given Moore's refusal to show her license, her movement towards the center console, and her active resistance. The court concluded that no clearly established law indicated that Wilson's use of force was excessive under the circumstances, thus entitling him to qualified immunity. View "Moore v. Oakland County" on Justia Law

Megan Miller was arrested and booked into the City of Troy’s pretrial detention facility, where she informed staff that she had been heavily using heroin and expected to go into withdrawal. Over the next two and a half days, Miller vomited continually. On the third day, she was found unconscious and unresponsive in her cell and was pronounced dead shortly after. Despite her continual vomiting, no jail official sought medical care for her, including Julie Green-Hernandez, who was responsible for monitoring detainees on the day of Miller’s death. Miller’s husband sued Green-Hernandez, claiming she violated Miller’s Fourteenth Amendment right to adequate pretrial medical care and acted with gross negligence under Michigan state law.The United States District Court for the Eastern District of Michigan denied Green-Hernandez’s motion for summary judgment, concluding she was not entitled to qualified immunity on the Fourteenth Amendment claim or state law immunity on the negligence claim. The court found that there were disputes of material fact regarding whether Green-Hernandez was deliberately indifferent to Miller’s serious medical needs and whether her conduct amounted to gross negligence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court dismissed Green-Hernandez’s appeal regarding qualified immunity due to lack of jurisdiction, as her arguments were based on factual disputes rather than purely legal questions. However, the court reversed the district court’s denial of Michigan governmental immunity. The Sixth Circuit held that while Green-Hernandez’s conduct could be considered grossly negligent, it was not the single most proximate cause of Miller’s death. The court concluded that Miller’s ingestion of fentanyl was the most immediate, efficient, and direct cause of her death, entitling Green-Hernandez to state law immunity. The case was remanded for further proceedings consistent with this opinion. View "Gillman v. City of Troy" on Justia Law

Michael and Rebecca McIntosh owned a mobile home park in Madisonville, Kentucky. In 2020, a tenant complained about mold and mildew in one of the mobile homes. The City of Madisonville inspected the home and found it unsafe, condemning it and giving the McIntoshes 30 days to submit repair plans. The McIntoshes disputed the condemnation, claiming they made necessary repairs and attempted to contact city officials multiple times without success. The City demolished the mobile home a month later.The McIntoshes pursued a § 1983 action, alleging due process violations. The district court granted summary judgment in favor of the City, leading the McIntoshes to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that while the City provided adequate notice of the condemnation, it failed to provide the McIntoshes with a pre-demolition hearing, as required by due process. The court noted that the City’s Code promised a hearing before a Local Appeals Board, which did not exist. The court also found that informal opportunities for a hearing were not adequately communicated to the McIntoshes. However, the court upheld the district court’s decision on the substantive due process claim, stating that the City’s actions did not rise to the level of conscience-shocking behavior. The court reversed the district court’s summary judgment on the procedural due process claim and affirmed the decision on the substantive due process claim, remanding the case for further proceedings on the procedural due process claim. View "McIntosh v. City of Madisonville" on Justia Law

Mark Blackwell criticized the city manager of Wayne, Michigan, leading the manager to complain to the police. Two officers convinced a prosecutor to charge Blackwell with stalking, but a judge acquitted him. Blackwell then sued the manager and officers, alleging they violated his First Amendment rights by inducing the prosecution in retaliation for his political speech. The district court found that Blackwell's complaint had enough facts to rebut the city officials' qualified-immunity defense at the pleading stage.The United States District Court for the Eastern District of Michigan denied the city officials' motion to dismiss, leading them to appeal. The district court refused to consider exhibits attached to the motion to dismiss and held that the complaint stated a plausible First Amendment retaliation claim. The court also found that qualified immunity would not protect the officials if Blackwell could prove his allegations.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court's decision to exclude the outside-the-complaint exhibits and found that Blackwell's complaint plausibly alleged a lack of probable cause for the stalking charge. The court held that the complaint sufficiently pleaded a First Amendment violation and that the law clearly established this violation. The court affirmed the district court's denial of the motion to dismiss, allowing Blackwell's claims to proceed. View "Blackwell v. Nocerini" on Justia Law

In 2005, Delano Hale was sentenced to death by an Ohio court for the murder of Douglas Green. Green was found dead in a motel room, wrapped in plastic bags, and had been shot multiple times. Hale was arrested driving Green's stolen vehicle and later admitted to the shooting, claiming it was in self-defense against Green's sexual advances. Hale was convicted of aggravated murder and other charges, and the jury recommended the death penalty.Hale's conviction and sentence were affirmed by the Ohio Supreme Court and the Ohio Court of Appeals. Hale filed for post-conviction relief, which was denied by the trial court and affirmed by the appellate court. He then sought federal habeas relief, raising multiple claims, including ineffective assistance of counsel and sentencing errors under Blakely v. Washington.The United States Court of Appeals for the Sixth Circuit reviewed Hale's habeas petition. The court denied Hale's claim of ineffective assistance of counsel, finding that his trial counsel's decision not to call a forensic expert was a reasonable strategic choice. The court noted that Hale's counsel had considered hiring an expert but ultimately chose a different strategy, which did not constitute deficient performance under Strickland v. Washington.The court also denied Hale's claim regarding his noncapital sentences, which were enhanced based on judicial factfinding in violation of Blakely. The Ohio Supreme Court had reviewed this claim for plain error and found no prejudice, concluding that a jury would have reached the same sentencing conclusions. The Sixth Circuit found this determination reasonable and upheld the Ohio Supreme Court's decision.The Sixth Circuit affirmed the district court's denial of Hale's habeas petition, concluding that Hale's claims did not warrant relief under the deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA). View "Hale v. Cool" on Justia Law