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

The case involves the family of Todd Kerchen, who died from a lethal dose of fentanyl. The family filed a complaint against the University of Michigan and Dr. James Woods, alleging violations under 42 U.S.C. § 1983 and Michigan state law. The family claimed that the fentanyl that killed Todd originated from a University of Michigan pharmacology lab where Christian Raphalides, the person who allegedly provided the drug to Todd, worked. The lab was overseen by Dr. Woods. The family argued that the lab's lax policies surrounding the use of controlled substances led to Todd's death.The district court denied the defendants' motion to dismiss and ordered limited discovery on whether the action was barred by the statutes of limitations applicable to the plaintiffs' claims. The defendants appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the University of Michigan and Dr. Woods in his official capacity were entitled to sovereign immunity, barring all claims against them. The court also found that Dr. Woods in his individual capacity was entitled to qualified immunity, barring the § 1983 claim against him. Furthermore, the court found that the wrongful death claim against Dr. Woods in his individual capacity should be dismissed as it was barred by governmental immunity. The court dismissed the remainder of the defendants' appeal for lack of jurisdiction. View "Kerchen v. University of Michigan" on Justia Law

This case involves a lawsuit filed by the family of Bill Heeter against Officer Kenneth Bowers and the Columbus Police Department. The family alleges that Officer Bowers used excessive force and violated Mr. Heeter's constitutional rights when he shot and killed Mr. Heeter during a police response to a suicide threat. The family also alleges that Officer Bowers violated Mr. Heeter's right to adequate medical care by failing to administer first aid after the shooting.The case was initially heard in the United States District Court for the Southern District of Ohio, where the defendants claimed immunity from the lawsuit. The district court granted the defendants immunity from some claims but denied others. The two constitutional claims against Officer Bowers that survived qualified immunity in the district court are the central focus of this appeal.The United States Court of Appeals for the Sixth Circuit affirmed the district court's denial of state-law immunity and qualified immunity as to Officer Bowers in his individual capacity, allowing the Heeters’ constitutional and state-law claims against him to proceed to trial. However, the court held that the City was entitled to summary judgment on the state-law claims because of an Ohio municipal immunity statute. The court reversed solely on the issue of municipal immunity for the City, and otherwise affirmed the district court's decision. View "Heeter v. Bowers" on Justia Law

The case involves Hattie Tanner, who was convicted of murder and served seventeen years in prison before her conviction was set aside due to insufficient evidentiary support. After her release, Tanner filed a lawsuit against David Walters, a retired police detective, alleging that he violated her constitutional rights by falsifying investigation reports and providing false testimony, leading to her wrongful conviction. Walters sought summary judgment based on qualified immunity, which the district court partially granted and partially denied. The court allowed Tanner's claims for fabrication of evidence and malicious prosecution to proceed to trial. Walters appealed this decision.Previously, the district court found that Tanner's claims for fabrication of evidence and malicious prosecution should proceed to trial. Walters appealed this decision, arguing that he was entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that a reasonable jury could conclude that Walters knowingly fabricated evidence against Tanner, and thus he was not entitled to qualified immunity on Tanner's fabrication-of-evidence claim. The court also found that a reasonable jury could find that Walters's false statements influenced the decision to charge Tanner, and that without these false statements, there would not have been probable cause to prosecute Tanner. Therefore, Walters was not entitled to qualified immunity on Tanner's malicious prosecution claim. View "Tanner v. Walters" on Justia Law

The case involves Kamel Chaney-Snell, who was arrested by Deputy Andrew Young and Officer Andrew Teichow during a search of his girlfriend's house. Chaney-Snell claimed that after he peacefully surrendered, Young punched him in the face, and one of the officers kneed him in the back and dragged him across the floor. He sued Young and Teichow under 42 U.S.C. § 1983, alleging excessive force and failure to intervene. The district court denied qualified immunity to both officers.The officers' appeals raised three questions. First, whether the court must accept Chaney-Snell’s claim that Young gratuitously punched him despite Chaney-Snell’s guilty plea for attempting to resist arrest. The Sixth Circuit found that it lacked jurisdiction over Young’s Heck claim, and his judicial-estoppel claim failed on the merits.Second, whether the Fourth Amendment allows officers to use unnecessary force on arrestees if the force qualifies as “de minimis”. The court held that gratuitous force violates the Fourth Amendment even if the force is minor and causes no serious injury.Finally, whether Chaney-Snell established a “failure to intervene” theory of liability. The court found that qualified immunity protects the officers from Chaney-Snell’s failure-to-intervene claims.The Sixth Circuit affirmed in part, reversed in part, and dismissed in part for lack of jurisdiction. View "Chaney-Snell v. Young" on Justia Law

The case revolves around the death of Darius Caraway, who overdosed while serving a murder sentence at Whiteville Correctional Facility in Tennessee, operated by CoreCivic, Inc. Caraway's estate, represented by his mother, sued CoreCivic and three of its officials, alleging that they violated Caraway's Eighth Amendment rights by failing to protect him from overdosing. The estate argued that CoreCivic deliberately understaffed the facility, leading to inadequate screening of prison guard applicants, smuggling of illegal drugs, and lack of supervision, which allowed fentanyl to proliferate at Whiteville. The estate claimed that the defendants knew about this proliferation but did nothing about it, leading to Caraway's death by overdose.The United States District Court for the Western District of Tennessee dismissed the estate’s complaint, stating that the claims were conclusory allegations of unconstitutional conduct devoid of well-pled factual support. The estate appealed this dismissal to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit affirmed the district court's decision. The court found that the estate failed to adequately allege that Caraway faced an objectively excessive risk of harm from unfettered access to drugs inside Whiteville. The court also found that the estate failed to sufficiently allege that the defendants knew of a drug problem at Whiteville or that they didn't reasonably respond to the alleged risk. The court concluded that the estate failed to meet the requirements of a failure-to-protect claim under the Eighth Amendment. The court also dismissed the estate's procedural claims, stating that the district court properly treated the motion as one to dismiss and that the estate had forfeited its argument about the district court's failure to issue a scheduling order. View "Caraway v. CoreCivic of Tennessee, LLC" on Justia Law

In this case, a taxi driver, Lufti Said Saalim, sued Walmart and several individuals, including deputy sheriffs, alleging violations of his Fourth and Fourteenth Amendment rights and state law claims following an incident at a Walmart in Toledo, Ohio. Saalim claimed that while waiting for his passengers at a loading zone, he was approached by a Walmart employee and subsequently by Deputy Sheriff Jeffrey Bretzloff, who was working as a private security guard for Walmart. Saalim alleged that Bretzloff used excessive force during the encounter, including pulling him out of his cab and using a taser on him.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision that granted Bretzloff qualified immunity on Saalim's Fourth Amendment claim. The court held that Saalim plausibly alleged that Bretzloff's use of force was unreasonable and violated the Fourth Amendment. The court also found that this right was clearly established at the time of the incident.However, the court affirmed the district court's dismissal of Saalim's Fourteenth Amendment claim, agreeing that it was identical to his Fourth Amendment claim. The court also affirmed the dismissal of Saalim's state law claims of assault, battery, intentional infliction of emotional distress, false arrest, and false imprisonment, as they were barred by the statute of limitations.The court remanded the case for further proceedings on Saalim's Fourth Amendment claim against Bretzloff; his § 1983 municipal liability claim against Sheriff Navarre; and his state law claims of negligent hiring, supervision, training, and retention and vicarious liability against the Walmart Defendants and McNett. View "Saalim v. Walmart, Inc." on Justia Law

In the case under review, the appellant, Lafayette Deshawn Upshaw, was convicted of crimes associated with two separate incidents occurring on the same day: a gas station robbery and a home invasion. Following exhaustion of state court remedies, Upshaw sought habeas relief in federal court, upon which the district court granted relief on claims of ineffective assistance of counsel and violation of the Batson rule.The ineffective assistance of counsel claim was based on trial counsel's failure to investigate potential alibi witnesses. The Batson rule violation claim was derived from the State’s use of peremptory challenges to strike six Black jurors. The Warden appealed the district court's decision, but the United States Court of Appeals for the Sixth Circuit affirmed the lower court's ruling.The court found that the trial counsel's failure to investigate potential alibi witnesses and to request an adjournment to rectify the situation was unreasonable and prejudicial to Upshaw, constituting ineffective assistance of counsel. The court also found that the State's failure to provide race-neutral reasons for striking certain jurors, coupled with the trial court's failure to properly evaluate the State's justifications, constituted a violation of the Batson rule. The court held that even a single racially motivated peremptory strike requires relief. The court concluded that both of these errors entitled Upshaw to habeas relief. View "Upshaw v. Stephenson" on Justia Law

In a case before the United States Court of Appeals for the Sixth Circuit, Thurman King sued Officers Zachary Abbate and Jason Bradley, the City of Rockford, the Rockford Public Safety Department, and other municipal officers under 42 U.S.C. § 1983 and state law for incidents stemming from a 2019 traffic stop. The district court granted partial summary judgment in favor of the defendants but denied their motion for summary judgment on qualified and governmental immunity grounds for King’s federal and state tort claims against Abbate and Bradley. The court also denied their motion on King’s Monell claim against the City and Department. The defendants appealed this denial.The Sixth Circuit affirmed in part, and reversed in part, the district court’s denial of qualified and governmental immunity to Abbate and Bradley. The court found that Abbate was entitled to qualified and governmental immunity for his takedown maneuver against King but not for the subsequent conduct on the ground. The court also dismissed the City and Department’s appeal for lack of appellate jurisdiction.The court found a genuine dispute of material fact as to whether Abbate and Bradley had probable cause to believe that King committed any underlying crimes, which defeated the officers' claims for summary judgment on King’s false arrest claim. The court affirmed the district court's denial of governmental immunity to Abbate and Bradley for their conduct on the ground but reversed the denial of governmental immunity to Abbate for his takedown maneuver. The court also affirmed the district court’s denial of governmental immunity to Abbate and Bradley for King’s false arrest claim. View "King v. City of Rockford, MI" on Justia Law

In this case, the plaintiff, Jason Schwebke, brought a lawsuit against his employer, United Wholesale Mortgage (UWM), alleging disability discrimination under state and federal law. Schwebke, who is deaf, claimed that UWM failed to provide him with necessary accommodations and retaliated against him. In response, UWM participated in extensive discovery procedures for several months without invoking its right to arbitration as per the parties' employment agreement.Seven months into the case, UWM moved to compel arbitration. The district court denied this motion, reasoning that UWM had implicitly waived its right to compel arbitration through its conduct. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision.The appellate court applied the principle from the Supreme Court's decision in Morgan v. Sundance, Inc., which held that a party may waive its contractual right to arbitrate by participating in litigation. In applying this rule, the court found that UWM's actions—participating in extensive discovery, failing to raise arbitration in its defense, and not moving to compel arbitration until seven months into the case—were completely inconsistent with reliance on the arbitration agreement. The court therefore concluded that UWM had implicitly waived its right to arbitration. View "Schwebke v. United Wholesale Mortgage LLC" on Justia Law

In this case, the plaintiff, Kellie Farris, called 911 alleging that another woman had damaged her car. However, responding sheriff's deputies ended up arresting Farris instead. Farris alleged that during her arrest and subsequent transportation to jail, the deputies used excessive force. She also claimed that she was suicidal and that the deputies' actions were unreasonable given her state of mind.In response, the deputies argued that they had probable cause for Farris's arrest based on corroborated eyewitness testimony and physical evidence in Farris's car. They further contended that Farris's suicidal behavior justified the level of force used to restrain and control her.On reviewing the case, the United States Court of Appeals for the Sixth Circuit agreed with the lower court's decision to grant summary judgment in favor of the defendants. The court found that the deputies had probable cause for Farris's arrest and that the force used was minimal and reasonably necessary given Farris's behavior. The court also rejected Farris's claim that the county had an unconstitutional policy of inadequately training its deputies, finding no evidence of deliberate indifference or a pattern of excessive force.The court noted that states may pass laws or prison policies that protect detainees' privacy or liberty more than the Constitution demands, but Farris failed to show how this was relevant to her Fourth Amendment claim.In conclusion, the Sixth Circuit affirmed the district court's decision, ruling in favor of the deputies and the county on all counts. View "Farris v. Oakland County" on Justia Law