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

A man with a documented history of severe mental illness and repeated suicide attempts was incarcerated in a Michigan jail after starting a fire at a psychiatric hospital in what was described as another suicide attempt. Lindsey O’Neil, who managed the jail’s mental-health unit, was aware of his recent hospitalization for suicidal ideation and past struggles but also observed that the strict suicide precautions—placement in a padded cell and a suicide-prevention gown—were causing him additional distress. Seeking to balance his mental health needs and suicide risk, O’Neil moved him to a less restrictive medical cell, allowed him to wear a regular jumpsuit, and ordered that he receive a suicide-prevention blanket instead of regular bedding. She also requested enhanced monitoring. Due to a miscommunication, jail staff gave him regular bedding, which he used to commit suicide.The man’s estate brought suit under 42 U.S.C. § 1983 and the Americans with Disabilities Act in the United States District Court for the Western District of Michigan, naming O’Neil, her employer, and others as defendants. The district court, adopting a magistrate judge’s recommendations, granted summary judgment to all defendants except O’Neil, finding that she was not entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that, at the time O’Neil acted, no clearly established law would have made it obvious to every reasonable official in her position that her compromise approach to housing the decedent constituted deliberate indifference to a known suicide risk. Thus, the Sixth Circuit concluded that O’Neil was entitled to qualified immunity, reversed the district court’s denial of that defense, and remanded the case for further proceedings. View "Lovell v. Cnty. of Kalamazoo" on Justia Law

A former member of a city council in Brecksville, Ohio, who owned a roofing company, participated in several council votes related to the construction of a new police station. His company was selected as the roofing subcontractor for the project, but he did not disclose his financial interest to the council. After his ownership came to light through the mayor’s review of project documents, the mayor and the city law director reported his actions to the Ohio Ethics Commission. The Ethics Commission investigated and ultimately referred the matter to the Cuyahoga County Prosecutor, resulting in a grand jury indictment on charges of unlawful interest in a public contract. The councilmember was acquitted after a bench trial. He alleged that the city officials had initiated the ethics complaint in retaliation for his public criticism of the council’s handling of a separate debt issue and that the officials had made false statements or omitted material facts in their communications with the Ethics Commission.The United States District Court for the Northern District of Ohio granted summary judgment to the individual officials and the city on all claims. On appeal, the plaintiff limited his arguments to his claims under 42 U.S.C. § 1983 for retaliatory prosecution and malicious prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court’s judgment. The court held that the grand jury indictment established a presumption of probable cause that the plaintiff was unable to rebut. The court found that, because the plaintiff voted on ordinances advancing the contract in which he had a financial interest, he could not invoke the relevant statutory affirmative defense. Additionally, the court ruled that the exception in Lozman v. City of Riviera Beach, 585 U.S. 87 (2018), did not apply, as the facts and legal context differed. The Sixth Circuit therefore affirmed the dismissal of all claims. View "Petsche v. Hruby" on Justia Law

After a series of violent crimes in Detroit, including a gas station robbery and a home invasion, police identified Derek Aaron as the primary suspect based on witness descriptions, security footage, and phone records. Officers located Aaron at a local gas station, where they attempted to arrest him without explicitly informing him of the arrest. Aaron, a large man, resisted by refusing to place his hands behind his back, repeatedly asking for an explanation, and physically pulling his arms away. The officers responded by taking him to the ground and using knee strikes to subdue him before successfully handcuffing him. Subsequent criminal charges against Aaron were dismissed, possibly due to his autism diagnosis, which was unknown to the officers at the time.Aaron, through his legal guardian, filed suit in the United States District Court for the Eastern District of Michigan, alleging that the officers used excessive force during the arrest and that other officers failed to intervene. The officers moved for summary judgment on the basis of qualified immunity. The district court granted qualified immunity on the failure-to-intervene claims but denied it on the excessive force claims, finding that a jury could determine the officers violated clearly established rights. The officers appealed the denial.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s denial of qualified immunity on the excessive force claims. The appellate court held that, given the seriousness of the suspected crimes, Aaron’s physical resistance, and the absence of a clearly established legal prohibition against the officers’ conduct under similar circumstances, the officers did not violate Aaron’s clearly established constitutional rights. Therefore, the officers were entitled to qualified immunity, and the district court’s order was reversed. View "Aaron v. King" on Justia Law

Several women incarcerated at a Michigan prison developed painful, persistent rashes between 2016 and 2019. Their complaints were largely ignored by prison staff, and medical providers initially misdiagnosed the condition, ruling out scabies, a highly contagious skin infestation. The prison’s contracted health care provider, Corizon Health, and its infectious disease coordinator were tasked with managing infectious diseases but failed to control the outbreak. Only after an outside dermatologist diagnosed scabies did prison officials begin widespread treatment and quarantine measures, though these efforts were not immediately effective. Four inmates who suffered from these conditions filed suit, seeking damages and injunctive relief against both the medical providers and high-level prison officials who had not directly treated them.The United States District Court for the Eastern District of Michigan denied motions for judgment on the pleadings by the Michigan Department of Corrections and Wayne State Officials. The district court held that the inmates had plausibly alleged that all defendants, including non-treating prison officials, committed clearly established Eighth Amendment violations and were not entitled to qualified immunity. The court also found that the gross negligence claims could proceed under Michigan law, as the complaint adequately alleged that the officials proximately caused the harms.On appeal, the United States Court of Appeals for the Sixth Circuit determined that, under existing precedent, non-treating prison officials’ reliance on contracted medical providers did not clearly constitute an Eighth Amendment violation. The court reversed the district court’s denial of qualified immunity on the inmates’ federal damages claims against these officials, finding no clearly established law requiring them to override medical judgments. However, the court affirmed the denial of state-law immunity, concluding that proximate cause under Michigan law could not be resolved at the pleading stage. The case was remanded for further proceedings consistent with these rulings. View "BLC Lexington SNF, LLC v. Townsend" on Justia Law

Daniel and Shatina Grady were arrested by police during a late-night shooting investigation outside a Michigan residence owned by their daughter. The Gradys lived nearby and approached the scene, filming officers and questioning their authority as they crossed into a perimeter that officers had established around the house suspected to contain the shooter. Despite receiving repeated commands to step back, the Gradys refused and continued to challenge the officers verbally. After warnings, the officers arrested them for interfering with the investigation, which led to a physical struggle.The Gradys were prosecuted in Michigan state court for assaulting, resisting, or obstructing the officers and damaging a police cruiser but were acquitted by a jury. While those charges were pending, the Gradys filed a civil suit in the United States District Court for the Eastern District of Michigan, raising several claims, including First Amendment retaliation. The district court found that the officers had probable cause to arrest the Gradys for failing to comply with lawful orders but allowed the First Amendment claim to proceed under the exception recognized in Nieves v. Bartlett. The district court concluded that the Gradys presented evidence that other bystanders, who had not criticized the police and were not arrested, were similarly situated.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of qualified immunity to the officers. The appellate court held that the other bystanders cited by the Gradys were not similarly situated because they did not enter the established perimeter or defy police orders. The court further found that the Gradys did not provide other objective evidence to satisfy the Nieves exception. As a result, the presence of probable cause defeated the Gradys’ First Amendment retaliatory arrest claim. The Sixth Circuit reversed the district court’s decision and remanded the case for further proceedings. View "Grady v. Cratsenburg" on Justia Law

An agent employed by Immigration and Customs Enforcement supervised participants in an Alternatives-to-Detention program, which allowed him significant discretion over their conditions, such as monitoring protocols and the handling of their passports. The agent engaged in sexual relations with multiple women under his supervision, violating agency policy. After one participant reported his behavior, an investigation revealed further evidence of misconduct, including deleted photos and communications. The agent attempted to impede the investigation by providing lenient supervision to a participant in exchange for her silence. One supervisee accused the agent of sexual assault, testifying to repeated coerced encounters.A jury in the United States District Court for the Southern District of Ohio convicted the agent on several counts, including depriving a person of constitutional rights under color of law, obstructing a sex-trafficking investigation, witness tampering, and destruction of records. The district court sentenced him to 144 months in prison. During trial, the court excused an ill juror during deliberations, which the defendant challenged as an abuse of discretion. He also argued that multiple counts were improperly multiplicitous, raising double jeopardy concerns, and challenged several sentencing enhancements.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the district court did not abuse its discretion in excusing the juror due to medical necessity. The appellate court found no plain error regarding multiplicity, as each contested count required proof of distinct elements or conduct. The court also upheld the sentencing enhancements, finding no error in applying an obstruction of justice enhancement to pre-investigation conduct under the amended Sentencing Guidelines, no impermissible double counting, and no error regarding the sentencing guidelines in relation to statutory maximums. The requirement that the defendant register as a sex offender was also affirmed. The Sixth Circuit affirmed the convictions and sentence in all respects. View "United States v. Golobic" on Justia Law

The case centers on a series of lawsuits initiated by an individual against the City of Athens, Tennessee, its officials, and employees, stemming from events related to the City’s annual fireworks show. In 2022, due to COVID-19 precautions, attendance at the show was restricted to City employees and their families. The plaintiff, objecting to the exclusion of the general public, attended the event in protest and began filming, which led to confrontations with City employees and ultimately police involvement. Subsequent disputes, including statements made by City officials regarding settlement negotiations and the cancellation of future fireworks shows, prompted the plaintiff to file multiple lawsuits alleging defamation and First Amendment retaliation.The United States District Court for the Eastern District of Tennessee reviewed the plaintiff’s claims in several cases. It granted summary judgment or dismissed the actions for failure to state a claim, rejected motions to recuse the assigned judges, and, in each case, awarded sanctions and attorneys’ fees to the defendants. The plaintiff and his attorney appealed the sanctions and recusal orders, but not the merits of the underlying claims, which had already been dismissed or affirmed in previous appeals or were unreviewable due to procedural defects. Prior appellate proceedings, including one in which the appeal was dismissed for failure to prosecute, precluded reconsideration of the underlying merits.The United States Court of Appeals for the Sixth Circuit reviewed only the sanctions and recusal orders. Applying abuse of discretion and de novo review where appropriate, the Sixth Circuit concluded that the district court properly denied recusal and correctly imposed sanctions. The appellate court found the plaintiff’s claims were frivolous, often barred by immunity or privilege, and part of a pattern of harassing litigation. The court affirmed the district court’s awards of attorneys’ fees under 28 U.S.C. § 1927, 42 U.S.C. § 1988, and Tennessee Code Annotated § 29-20-113, as well as the denial of the recusal motions. View "Whiting v. City of Athens" on Justia Law

James Williams, at midnight on New Year’s Day in Canton, Ohio, fired numerous shots into the air from a patio enclosed by a wooden privacy fence as part of a celebratory tradition. Officer Robert Huber, responding to the gunfire, arrived at the scene and witnessed Williams begin a second round of shooting. Without announcing his presence or issuing a warning, Huber shot Williams through the fence, resulting in Williams’s death. Williams’s wife sued Huber and the City of Canton, alleging excessive force under the Fourth Amendment and municipal liability.The United States District Court for the Northern District of Ohio reviewed Huber’s motion for summary judgment based on qualified immunity. The court determined that there was a genuine dispute of material fact regarding whether Williams had turned his rifle toward Huber or continued firing into the air, and whether celebratory gunfire was common in Canton at that time. Based on these unresolved factual questions, the district court denied Huber’s motion for summary judgment, finding that a reasonable jury could conclude Huber lacked probable cause to believe Williams posed a threat sufficient to justify deadly force.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of summary judgment. The Sixth Circuit held that, construing the facts in the light most favorable to Williams’s wife, Huber violated the Fourth Amendment by using deadly force without probable cause to believe Williams posed a threat of serious physical harm. The court further concluded that this violation was clearly established law in an “obvious” case, as no reasonable officer would have believed it permissible to shoot a person committing a misdemeanor—discharging a gun into the air in celebration—without warning or evidence of a threat. View "Williams v. City of Canton" on Justia Law

A company sought to erect a digital billboard in a small Ohio municipality but was prevented from doing so by the local billboard ordinance, which included restrictions on size, location, and type of billboards permitted. The ordinance specifically banned “variable message” (digital) signs and implemented a “cap and replace” rule, allowing new billboards only if older ones were removed. The ordinance also contained several exemptions, including one for “public service” signs, which were allowed to display information like time or weather if not used for advertising.Previously, the United States District Court for the Southern District of Ohio granted summary judgment to the municipality, upholding the ordinance against the company’s First Amendment challenges. On appeal, the United States Court of Appeals for the Sixth Circuit determined that the exemption for public service signs was an unconstitutional, content-based restriction under the First Amendment, but remanded the case for the district court to determine whether the invalid exemption was severable from the rest of the ordinance.On remand, the district court found that the unconstitutional provision could be severed and that the remainder of the ordinance survived intermediate scrutiny, granting judgment again in favor of the municipality. The company appealed.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the public-service exemption was severable under Ohio law, applying the three-part test from Geiger v. Geiger. The court further held that the remaining provisions of the ordinance were content-neutral and survived intermediate scrutiny because they were narrowly tailored to significant governmental interests such as traffic safety and aesthetics. The court also held that the company was not entitled to damages or attorney fees, as it was not a prevailing party under 42 U.S.C. § 1988(b). View "Norton Outdoor Advertising, Inc. v. Village of St. Bernard" on Justia Law

A man was convicted by a Michigan state jury for delivering oxycodone to a friend, resulting in her death from a drug overdose. The evidence showed that the man and the deceased had a longstanding relationship, and after her release from jail, he purchased 40 Percocet pills—containing oxycodone and acetaminophen—and spent time with her at a hotel where she died. Medical experts found oxycodone in her blood and acetaminophen in her urine, both components of Percocet, and testified that oxycodone was a substantial factor in causing her death.After his conviction, the defendant sought a new trial in the Michigan courts, arguing that his trial counsel was ineffective for two reasons: failing to investigate an “acetaminophen-based” defense (that the absence of acetaminophen in the blood meant the deceased had not consumed Percocet), and failing to call an expert witness to challenge the prosecution’s case on causation. The trial court held a hearing and ultimately rejected these claims. The Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied further review.The United States District Court for the Eastern District of Michigan then denied the defendant’s petition for habeas corpus, and the case was appealed to the United States Court of Appeals for the Sixth Circuit. The Sixth Circuit held that, under the highly deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA), the state courts did not unreasonably apply clearly established Supreme Court law or make unreasonable determinations of fact in rejecting the ineffective assistance claims. The court further held that counsel’s strategic decisions were not objectively unreasonable and that the alleged failures did not prejudice the outcome of the trial. The Sixth Circuit affirmed the denial of habeas relief. View "DeBruyn v. Douglas" on Justia Law