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

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

HRT Enterprises pursued a takings claim against the City of Detroit after losing a jury verdict in state court in 2005. Subsequently, HRT filed suit in federal court in 2008, alleging a post-2005 violation under 42 U.S.C. § 1983. The United States District Court for the Eastern District of Michigan dismissed the federal action, citing the requirement from Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985), to exhaust state remedies first. HRT then returned to state court, where its claim was dismissed on claim preclusion grounds, a decision affirmed by the Michigan Court of Appeals. After the state court denied compensation, HRT initiated a federal § 1983 action in 2012. The case was stayed when the City filed for bankruptcy, prompting HRT to participate in bankruptcy proceedings to protect its compensation rights. Ultimately, the bankruptcy court excepted HRT’s takings claim from discharge, allowing the federal case to proceed. After two jury trials, the district court entered judgment for HRT in September 2023.Following its success, HRT moved for attorney fees under 42 U.S.C. § 1988, presenting billing records that included work from related state and bankruptcy proceedings. The district court applied a 33% discount to the claimed hours due to commingled and poorly described entries, set an average hourly rate, and awarded $720,486.25, which included expert witness fees. Both parties appealed aspects of the fee award to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit held that the district court erred by concluding it had no discretion to award fees for work performed in the related state-court and bankruptcy proceedings, as such fees are recoverable when the work is necessary to advance the federal litigation. The court also found the district court erred in awarding expert witness fees under § 1988(c) in a § 1983 action, as the statute does not authorize such fees for § 1983 claims. The appellate court vacated the fee award and remanded for recalculation consistent with its opinion. View "HRT Enterprises v. City of Detroit" on Justia Law

The plaintiff was incarcerated in Tennessee on sentences from multiple convictions. After being granted parole by the Tennessee Board of Parole, he was not released on his effective parole date because county officials filed a detainer warrant, claiming he had not completed his sentence and was required to serve additional time in county jail. The plaintiff remained in custody for over four months beyond his scheduled release date. He and his family attempted to resolve the situation, and he eventually retained counsel, after which the detainer was lifted and he was released.The plaintiff brought suit in the United States District Court for the Western District of Tennessee against the county, several county officials, state officials, and unnamed defendants under 42 U.S.C. § 1983, alleging violations of his rights under the Fourth and Fourteenth Amendments, as well as state law. The county defendants moved to dismiss for failure to state a claim and asserted qualified immunity. The plaintiff voluntarily dismissed his claims against the state defendants. The district court granted the county defendants’ motion to dismiss, holding that there was no liberty interest in release on parole under Tennessee law, that the individual defendants were entitled to qualified immunity, and that no plausible claim was stated against the county under Monell v. Department of Social Services. The court declined to exercise supplemental jurisdiction over the state law claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit held that Tennessee’s statutory scheme does not create a protected liberty interest in parole or in release following a grant of parole. Without such a liberty interest, the plaintiff’s due process claim failed, and the individual defendants were entitled to qualified immunity. The Monell claim against the county also failed in the absence of an underlying constitutional violation. The appellate court affirmed the district court’s refusal to exercise supplemental jurisdiction over the state law claims. The judgment of the district court was affirmed. View "Hester v. Chester County" on Justia Law

After a fatal school shooting occurred at a high school in Michigan, H.H., an eighth-grade student at a different school, was reported by several classmates to have made threatening comments about possessing or bringing a gun to campus. The school administration, in response to these reports and heightened safety concerns, questioned H.H. with assistance from law enforcement, searched his person, backpack, and locker, and ultimately found no firearm. Despite this, the administration determined that H.H. had violated the school district’s code of conduct and referred him for an expulsion hearing, which resulted in his expulsion for 180 days.Following the expulsion, H.H.’s parents filed a lawsuit in the United States District Court for the Eastern District of Michigan against the school district and various officials. They raised claims under 42 U.S.C. § 1983 for alleged violations of H.H.’s Fourth Amendment rights (unlawful search and seizure), procedural and substantive due process, and also asserted state law tort claims. The district court granted summary judgment in favor of the defendants on all claims, finding no constitutional violations and determining that the defendants were immune from state law liability.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the search and seizure of H.H. were reasonable under the circumstances, given the nature of the reported threat and school safety concerns. It found that the procedures afforded to H.H. during the expulsion process satisfied due process requirements, and there was no evidence of bias or arbitrary conduct by the school board. The court also concluded that the individual defendants were entitled to qualified immunity, and that governmental immunity barred the state tort claims. The Sixth Circuit affirmed the district court’s judgment in full. View "Halasz v. Cass City Public Schools" on Justia Law

Luther Poynter was incarcerated at the Barren County Detention Center in Kentucky for contempt of court related to unpaid child support. After a brief period in COVID-19 observation, he was moved to a general-population cell with two other detainees, Scotty Wix and Timothy Guess. Both Wix and Guess had extensive histories of violent behavior and multiple documented assaults against other detainees while in the facility. Shortly after Poynter entered the cell, Guess and Wix attacked him without apparent provocation, causing a traumatic brain injury and lasting physical impairment.The United States District Court for the Western District of Kentucky reviewed the case after Poynter, through his guardian, sued the jailer and Barren County under 42 U.S.C. § 1983, alleging deliberate indifference to his safety in violation of the Due Process Clause of the Fourteenth Amendment. The district court granted summary judgment to the county, concluding there was insufficient evidence of a constitutional violation or municipal liability, and held that Poynter had not shown he was placed at a substantial risk of harm or that reasonable steps were not taken to abate that risk.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. The appellate court held that Poynter had presented sufficient evidence for a reasonable jury to find that Barren County had a custom of failing to properly classify detainees with violent histories, recklessly disregarded a known risk, and that this failure caused Poynter’s injuries. The Sixth Circuit clarified that municipal liability can attach even without identifying a specific individual as the violator, so long as the unconstitutional harm resulted from a municipal policy or custom. The Court of Appeals reversed the district court’s summary judgment and remanded the case for further proceedings. View "Poynter v. Bennett" on Justia Law

A fast-casual restaurant chain hired an individual with arthritis in her knees for a cashier/service-team member position. Prior to starting, she requested to be allowed to sit for five minutes after every ten minutes of standing, due to her medical condition. The restaurant required employees in her role to multitask and maintain mobility throughout their shifts, handling various duties such as operating the register, restocking, cleaning, and serving customers. The employer concluded that her requested accommodation would prevent her from performing essential job functions and did not permit her to begin work until the accommodation issue was resolved.The United States District Court for the Eastern District of Kentucky reviewed the case after the employee sued under the Americans with Disabilities Act (ADA) and the Kentucky Civil Rights Act (KCRA), alleging failure to accommodate her disability and failure to engage in the interactive process. The district court granted summary judgment to the employer, holding that the requested accommodation was not reasonable as a matter of law, and that her claim regarding the interactive process could not proceed without a viable accommodation claim.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court affirmed, holding that the employee’s proposed accommodation—sitting for five minutes after every ten minutes of standing—was not objectively reasonable because it would fundamentally alter essential functions of the cashier/service-team member position, which required continuous mobility and multitasking. The court further held that, because no reasonable accommodation was shown, the claim arising from the employer’s alleged failure to engage in the interactive process also failed as a matter of law. The judgment of the district court was therefore affirmed. View "Bowles v. SSRG II, LLC" on Justia Law

The plaintiffs in this case are mental health counselors who provide “talk therapy” services, including counseling to minors, guided by their Catholic faith. Their services consist exclusively of spoken words, and they do not use physical or aversive techniques. Some of their clients, including minors with parental consent, seek counseling to address issues related to gender identity or sexual orientation, such as wanting to align their gender identity with their biological sex or to reduce same-sex attraction in accordance with their religious beliefs. The plaintiffs assert an ethical and religious duty to help clients pursue such goals if requested.In 2023, Michigan enacted laws forbidding licensed therapists from engaging in “conversion therapy” with minors, defined as efforts to change an individual’s sexual orientation or gender identity, but specifically permitting counseling that assists with gender transition. The plaintiffs filed suit in the United States District Court for the Western District of Michigan, seeking a preliminary injunction to block enforcement of these laws, arguing that the prohibition restricts their speech based on its content and viewpoint in violation of the First Amendment. The district court denied the motion, reasoning that the counseling in question was conduct, not speech, for constitutional purposes.On appeal, the United States Court of Appeals for the Sixth Circuit found that the plaintiffs had standing and disagreed with the district court’s characterization of the therapy as conduct rather than speech. The court held that the Michigan law is a content- and viewpoint-based restriction on speech and is therefore subject to strict scrutiny under the First Amendment. The court determined that the State did not demonstrate a sufficient justification for the restriction, and that the plaintiffs are likely to succeed on the merits of their claim. The Sixth Circuit reversed the district court’s denial of the preliminary injunction and remanded for prompt entry of an injunction preventing enforcement of the law during the case. View "Catholic Charities of Jackson v. Whitmer" on Justia Law

In this case, an individual attended the 2022 Kentucky Derby in Louisville, Kentucky, with a group to engage in expressive activities such as preaching, distributing literature, and displaying signs near the event. The area surrounding Churchill Downs was subject to a special event permit issued by the city government, which allowed Churchill Downs to restrict access to certain public streets and sidewalks to ticket holders and credentialed individuals. The plaintiff and his group entered a fenced-off, restricted area beyond posted “No Trespassing” signs, despite lacking event tickets or credentials. After repeated warnings from private security and law enforcement, the plaintiff was arrested by a Kentucky State Police trooper for criminal trespass.The plaintiff filed suit in the United States District Court for the Western District of Kentucky, asserting claims under 42 U.S.C. § 1983 for violations of his free speech, free exercise, and due process rights, as well as a Monell municipal liability claim against the city government and claims against the arresting officer. The district court granted summary judgment in favor of the defendants on all claims. It found the free speech restriction content-neutral and justified under intermediate scrutiny, concluded the free exercise claim was not properly developed, determined the permitting scheme was not unconstitutionally vague, dismissed the Monell claim for lack of an underlying constitutional violation, and granted qualified immunity to the arresting officer.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the restricted area was a limited public forum and the ticketing and access restrictions were content-neutral and survived intermediate scrutiny. The court found no evidence of viewpoint discrimination, held that ample alternative channels for communication existed, and determined that the plaintiff failed to preserve his free exercise claim and did not establish a due process violation. The Monell claim failed for lack of a constitutional violation, and qualified immunity was properly granted to the officer. View "Blankenship v. Louisville-Jefferson Cnty. Metro Gov't" on Justia Law

The plaintiff claimed that Michigan had taken custody of between $200 and $600 in unclaimed property belonging to her. She alleged that, under Michigan’s Uniform Unclaimed Property Act, the state would return her property if she requested it but would not pay her any interest earned while the property was in the state’s custody, unless the property was originally interest bearing. Without first submitting a claim to reclaim her property, she brought a suit under 42 U.S.C. § 1983 against officials responsible for Michigan’s unclaimed property program, arguing that the state’s failure to pay interest amounted to an unconstitutional taking in violation of the Fifth Amendment. She sought declaratory and injunctive relief on behalf of herself and a putative class.The United States District Court for the Eastern District of Michigan dismissed her case, concluding that she lacked Article III standing because Michigan law did not grant her a property right to interest earned on her unclaimed property. The district court reasoned that, without such a property right, she could not demonstrate an injury from the state’s retention of interest.On appeal, the United States Court of Appeals for the Sixth Circuit found that the plaintiff had standing, as her complaint alleged a concrete financial injury: the state’s withholding of interest that she claimed was rightfully hers. The court held that the district court improperly conflated the merits of whether she was entitled to interest with the standing inquiry. The Sixth Circuit reversed the district court’s dismissal for lack of standing and remanded for further proceedings, emphasizing that the record was insufficient to resolve the merits of the takings claim at this stage. View "Hendershot v. Stanton" on Justia Law

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law