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

The State of Tennessee operated the Arlington Developmental Center, an institutional home for people with mental disabilities. In 1992, the United States sued Tennessee under the Civil Rights of Institutionalized Persons Act alleging that, among other things, Tennessee had failed to provide Arlington’s residents with adequate food, medical care, supervision, and shelter. After a trial on the merits, the district court found that Arlington’s conditions violated the due-process rights of its residents. The court ordered the State to submit a plan to improve conditions there. Since then, People First of Tennessee has presented 19 applications for attorneys’ fees to the district court. Tennessee consented to pay every dollar of fees requested in the first 18 applications filed by intervenors-appellees People First of Tennessee (a total of about $3.6 million, including over $400,000 for the period at issue here). But the State objected to People First’s 19th application, which for the most part sought fees for a contempt motion that the district court had stricken from the docket and that People First never renewed. The 19th application also sought fees for hours that People First’s attorneys had chosen to spend monitoring the State’s compliance with the consent decree, even though the State had already paid $10.6 million in fees to a monitor whom the court had appointed for that same purpose. Despite those circumstances, the district court awarded People First $557,711.37 pursuant to the application, holding that People First had been a “prevailing party” with respect to its contempt motion. The State appealed the district court's award. After review, the Sixth Circuit disagreed with the district court's judgment, reversed and remanded. View "United States v. Tennessee" on Justia Law

The website for InterVarsity Christian Fellowship/USA states that all employees must annually reaffirm their agreement with IVCF’s Purpose Statement and Doctrinal Basis. The website includes statements that: Pursuant to the Civil Rights Act of 1964 (42 U.S.C. 2000e-1(a)) (Title VII), IVCF has the right to, and does, hire only candidates who agree with IVCF’s Purpose and Doctrinal Basis and that the status of [IVCF] as an Equal Opportunity Employer does not prevent the organization from hiring staff based on their religious beliefs so that all staff share the same religious commitment. Conlon began working at IVCF in Michigan in 1986 as a spiritual director, involved in providing religious counsel and prayer. In 2011, she informed IVCF that she was contemplating divorce. IVCF put her on paid (later unpaid) leave. When her marital situation continued to worsen despite counseling efforts, IVCF terminated her employment. After exhausting administrative remedies, Conlon sued IVCF and her supervisors under Title VII and Michigan law, alleging that male employees were treated differently. IVCF claimed ministerial exception to employment laws. The district court dismissed, holding that the First Amendment’s ministerial exception barred all of Conlon’s claims. The Sixth Circuit affirmed. View "Conlon v. InterVarsity Christian Fellowship/USA" on Justia Law

In 2009, Pontiac Officer Lasseigne shot and killed Craft, a 14-year-old male after responding to a 911 call, reporting males with guns were walking west on Ypsilanti Avenue. Officers testified that Craft ran from Ypsilanti Avenue, drawing a gun, and that he aimed a gun at the officers. The district court rejected several claims in a 42 U.S.C. 1983 suit filed by Craft’s estate, but denied Lasseigne’s motion for summary judgment, finding that he was not entitled to qualified immunity or governmental immunity under Michigan law because there was a genuine dispute regarding whether Craft was holding the shotgun when he was shot. The court noted that Craft was shot only once, while officer training protocol would call for multiple shots in the face of imminent danger; that still shots from the police video depict Craft pinned–at least to some extent–to the fence; and that the weapon did not have any blood on it, while both the fence and vehicle were splattered with blood. The Sixth Circuit dismissed appeal of the denial of summary judgment, affirmed denial of governmental immunity, and remanded. View "Harris v. Lasseigne" on Justia Law

Former county administrators of elections from eight Tennessee counties in Tennessee filed suit under 42 U.S.C. 1983, alleging that after the 2008 statewide elections and a shift in the controlling political party in the state assembly, they were ousted from their positions by the defendants, county election commissioners, because of their actual or perceived political party affiliation. The district court held that the statutory position of county administrator of elections in Tennessee is lawfully subject to patronage dismissal under Elrod v. Burns, 427 U.S. 347 (1976), and Branti v. Finkel, 445 U.S. 507 (1980). The Sixth Circuit affirmed the dismissal. All of the identified duties of the administrator that involve policy matters are matters of political concern. Administrators spend a significant portion of time advising the commissioners on how to exercise their statutory policymaking authority, including apprising the commissioners of current laws and changes in the law, assisting in reapportionment matters, preparing the annual budget, and overseeing election operations, and control the lines of communications to the commissioners. View "Peterson v. Dean" on Justia Law

Yeager filed a complaint alleging that the defendant discriminated against him on the basis of his religion, in violation of Title VII of the Civil Rights Act and Ohio Revised Code Chapter 4112, by refusing to hire him or by terminating his employment because he failed to provide a social security number. Yeager alleged that he had no social security number because he had disclaimed and disavowed it on account of his sincerely held religious beliefs. The district court dismissed. The Sixth Circuit affirmed. Under either Title VII or Chapter 4112 Yeager was required to prove that he holds a sincere religious belief that conflicts with an employment requirement; he has informed the employer about the conflicts; and he was discharged or disciplined for failing to comply with the conflicting employment requirement. If Yeager established his prima facie case, his employer has the burden to show that it could not “reasonably accommodate” his religious beliefs without “undue hardship.” An employer is not liable when accommodating an employee’s religious beliefs would require the employer to violate federal law. View "Yeager v. FirstEnergy Generation Corp." on Justia Law

Tilley, 59 years old, began working for the Road Commission in 1993. In 2008, Tilley began reporting principally to Bartholomew, the Commission’s general superintendent. After several disputes between the two, Tilley was fired. He sued, alleging termination based on his age in violation of Michigan’s Elliot-Larsen Civil Rights Act, M.C.L. 37.2201, and that the Road Commission interfered with his right to, and retaliated against him for taking, medical leave under the Family Medical Leave Act, 29 U.S.C. 2601. The district court granted the Road Commission’s motion for summary judgment on all of Tilley’s claims. The Sixth Circuit affirmed summary judgment on Tilley’s ELCRA age-discrimination claim, but reversed summary on Tilley’s claims under the FMLA. Tilley presented sufficient evidence to create a material factual dispute on his claim that the Road Commission was equitably estopped from denying that he was covered under the FMLA. Because the district court granted summary judgment on the basis that Tilley was not an “eligible employee,” it did not address the other bases on which the Road Commission sought summary judgment on Tilley’s FMLA interference and retaliation claims. View "Tilley v. Kalamazoo Cnty. Road Comm'n" on Justia Law

Tanner was convicted of a 1995 robbery and stabbing murder. The appeals court reversed for failure to provide DNA and serology experts. The Supreme Court of Michigan reversed. Tanner’s federal habeas petition was dismissed in 2005. Tanner, who is illiterate, then met with a legal assistant and requested a prison certificate of account, for her motion to file in forma pauperis. The assistant received that document on December 5, while Tanner’s unit was on lockdown. The legal assistant scheduled a “call-out” for December 6, so that Tanner could sign and file within the 30-day appeal period (FRAP 4(a)(1)(A)). Tanner told guards that she needed to pick up legal papers, but they refused. On December 8 Tanner signed the notice and delivered it to the mailroom for expedited handling the following day. Her notice was considered filed on December 9, 31 days after entry of judgment. The district judge granted a certificate of appealability on December 23. Tanner’s habeas appeal was docketed on January 9, beyond the last day on which Tanner could request extension of the 30-day period. On January 20, the Sixth Circuit issued a show-cause order. Tanner explained that guards had prevented timely filing. The Sixth Circuit dismissed. In 2007, Tanner filed a civil rights action against the guards. In 2012, a jury awarded damages. Tanner moved for relief under FRCP 60(b)(6), which permits a district court to “relieve a party . . . from a final judgment … for . . . any . . . reason.” The court denied the motion, ruling that Rule 4(a)(1) is jurisdictional. The Sixth Circuit reversed, emphasizing that the court will be granting relief “to revive a lost right of appeal,” not granting an extension under Rule 4(a)(5). View "Tanner v. Yukins" on Justia Law

In 1983, Clifton was convicted of grand larceny, found to be a habitual criminal, and sentenced to life in prison. In 2010, Clifton was paroled. Tennessee’s Court Cost Center sent Clifton an invoice for $124 in outstanding court costs. Clifton attempted to pay and contacted the Center to establish a payment plan. Months later, the Board of Probation and Parole issued an arrest warrant, alleging that Clifton had engaged in “intimidating and threatening behavior.” After a hearing, the board recommended parole revocation. His appeal was denied. Although his certiorari petition was timely, the court clerk refused it because Clifton had unpaid court costs. A notice of appeal was returned unfiled for the same reason, referring to costs totaling $1,449; the decision complied with a chancery court Standing Order, which refers to Tenn. Code 41-21-812. Clifton filed a pro se habeas corpus petition. The district court acknowledged Clifton’s contention that he was unfairly prevented from filing his state appeal, but concluded that the claims were procedurally defaulted and that Clifton had not established “cause” and “prejudice” to overcome that default. The Eighth Circuit held that Tennessee may not constitutionally require that prior expenses be paid in full before permitting a prisoner to file a habeas petition challenging the constitutionality of probation revocation. View "Clifton v. Carpenter" on Justia Law

Gumm is mentally retarded, with an IQ of approximately 70. He was convicted of the kidnapping, attempted rape, and murder of a 10-year-old and was sentenced to death. His convictions and sentences were affirmed on direct appeal, and his post-conviction petition was found to lack merit by the Ohio state courts. After he sought federal habeas corpus, the U.S. Supreme Court decided in Atkins v. Virginia, 536 U.S. 304 (2002) that persons who are mentally retarded cannot be executed. In a post-Atkins petition, Ohio courts adjudicated Gumm mentally retarded and reduced his sentence to 30 years to life in prison, but rejected non-Atkins claims. On federal habeas review, the court granted a conditional writ of habeas corpus on claims that the government failed to disclose exculpatory evidence as required by Brady v. Maryland; that Gumm received an unfair trial due to improper admission of incendiary prior bad acts evidence; that admission of a psychiatric report violated the Sixth Amendment’s Confrontation Clause; and that the prosecutor’s elicitation of inflammatory testimony and admission of psychiatric reports constituted prosecutorial misconduct. The Sixth Circuit affirmed the grant of the conditional writ of habeas corpus based on Gumm’s Brady and prosecutorial misconduct claims. View "Gumm v. Mitchell" on Justia Law

Despite the complete absence of physical evidence and Bies’ repeated proclamations of innocence, Bies was convicted and sentenced to death in Ohio state court in 1992 for the kidnapping, assault, and urder of a 10-year-old boy. The case against Bies rested almost entirely upon an unrecorded statement that Bies allegedly made to the police following a prolonged and highly suggestive custodial interrogation. The Ohio courts upheld Bies’ convictions on direct appeal and in post-conviction proceedings, but vacated Bies’ death sentence after determining that he is intellectually disabled, and that his execution is barred by the Eighth Amendment. In a petition for a writ of habeas corpus under 28 U.S.C. 2254, Bies challenged his convictions and sought a new trial. He claims that the government withheld exculpatory evidence in violation of Brady; that the trial court improperly allowed Bies’ custodial statements to be admitted at trial; and that Bies’ attorney rendered ineffective assistance of counsel. The district court granted a conditional writ of habeas corpus based on the Brady violation, and denied relief on the remaining claims. The Sixth Circuit affirmed as to the Brady claim, and declined to consider the remaining claims. View "Bies v. Sheldon" on Justia Law