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

In 1991, Jackson was wrongfully convicted of murder. In 2016, the Innocence Project requested from the Cleveland Police documents relating to the investigation, pursuant to the Ohio Public Records Act. Receiving no response, Innocence Project sent a request to the Cuyahoga County Prosecutor’s Office. Assistant Prosecuting Attorney Marburger produced a heavily redacted file. The Act exempts “investigatory work product” and “[t]rial preparation record[s]” from production as public records. Months later, the Ohio Supreme Court held that the investigatory-work-product exception did not extend beyond the conclusion of a trial. Cleveland then produced the unredacted file, which included significant exculpatory evidence. The Cuyahoga County Prosecutor’s Office also produced an unredacted file. A state-court judge vacated Jackson’s conviction. In 2019, he was finally exonerated. Jackson filed suit under 42 U.S.C. 1983. Against Marburger, Jackson alleged denial of access to courts.The Sixth Circuit held that Marburger is not entitled to absolute immunity. Responding to a records request after the conclusion of a trial and appeal is not an action that is an inherent part of a prosecutor’s adversarial function. The court reversed the denial of qualified immunity. Jackson plausibly stated a claim that Marburger violated his right of access to the courts when she removed exculpatory information from the file and effectively prevented him from filing for postconviction relief but in 2016 it was not clearly established that redacting exculpatory information from a response to a public-records request effectively covered-up evidence. View "Jackson v. City of Cleveland" on Justia Law

In 1987, a Michigan jury convicted Burton of first-degree murder and a firearm charge. He was sentenced to life in prison without the possibility of parole. In 2019, Burton was released from prison and his conviction was vacated on the prosecutor’s motion after key witnesses recanted and details of witness manipulation and intimidation were revealed. Detective Sanders’s investigative tactics allegedly included threats and physical violence against witnesses, including minors. In 2020,Burton filed claims under 42 U.S.C. 1983 and 1988 against Sanders and Detroit for Brady violations, malicious prosecution, and fabrication of evidence. The district court dismissed Burton’s claims as barred by Detroit’s Chapter 9 bankruptcy which occurred after Burton’s claims arose. Burton’s claims against Sanders remain pending. Burton’s sons then filed suit against Sanders and the city, alleging that the wrongful conviction and incarceration of their father throughout their childhood and into adulthood violated their constitutional right to family integrity. The district court dismissed, finding no cognizable due process right for “interference with family integrity” when a party is indirectly harmed by a constitutional tort against a family member. The Sixth Circuit affirmed; the plaintiffs have not alleged that the defendants acted with a culpable state of mind, directed toward them or their family unit. View "Chambers v. Sanders" on Justia Law

A man walked into Walgreens wearing clothes with white stains, placed a pack of gum on the counter, asked for cigarettes, then pulled out an apparent handgun. The man fled with the money and the cigarettes, leaving the gum. Police found Jacobs’s fingerprint on the gum and got an arrest warrant. Jacobs learned of the warrant and voluntarily went to the police station. Jacobs met with Detective Agee, who read him his Miranda rights. Showing Jacobs pictures from the Walgreens robbery and other robberies, Agee noted that the stains on the robber’s clothes resembled stains on Jacobs’s jacket. Jacobs denied involvement in the robberies. Agee highlighted the strength of the fingerprint evidence and said that he would get a warrant to search Jacobs’s dad’s house, where Jacobs was living, and Jacobs’s car. Agee said that Jacobs would likely face a severe sentence but things might be different if Jacobs changed his story. Jacobs then said: “The weapons—them is gone.” Agee gave Jacobs a phone to make calls and offered food and drink. After a break, Jacobs said he “f—ed up bad” because he was “broke” and needed to pay child support. He made statements about the gun and helped police retrieve the clothes from his girlfriend’s house. The interview lasted less than two hours.The district court granted Jacobs’s suppression motion, concluding that Agee used impermissibly coercive tactics. On interlocutory appeal, the Sixth Circuit reversed. Jacobs’s statements were voluntary. View "United States v. Jacobs" on Justia Law

A 2008 Michigan initiative decriminalized marijuana for medical purposes; a 2016 law afforded legal status to medical marijuana dispensaries. In Detroit, the Buildings, Safety Engineering, and Environmental Department (BSEED) screened applications for such facilities. The code prohibits locating such a facility in a drug-free zone–an area “within 1,000 radial feet of the zoning lot” containing any one of several "sensitive places," including a school.Genie applied to run a medical marijuana distribution facility on Mack Avenue in Detroit. BSEED denied the application at the screening stage because the proposed site was in a drug-free zone based on a lot (in the neighboring community of Grosse Point Park) on which St. Clare School sits. Genie unsuccessfully challenged the determination through state administrative and judicial channels. Detroit deemed the St. Clare’s “zoning lot” to include land where the parish church sits (the church and school have separate lots of record), all of which is listed under a single tax parcel number.Genie sued in federal court, arguing that Detroit erred in measuring the distance between the proposed Genie site and St. Clare’s while approving other sites in violation of the equal protection and due process guarantees. The Sixth Circuit affirmed summary judgment in favor of Detroit. Genie had no property interest in its proposed facility. Detroit applied the same method of measurement to each comparable applicant. Although Genie cited two applications that were approved, many applications were rejected on that basis. View "Green Genie, Inc. v. City of Detroit" on Justia Law

In 2019, Morgan began employment as Disciplinary Counsel for the Board of Professional Responsibility of the Supreme Court of Tennessee. During a disciplinary proceeding, Manookian, whose law license had been suspended, moved to disqualify Morgan as the Board’s counsel, claiming that Morgan was “an anti-Muslim bigot.” Manookian’s filing attached tweets posted by Morgan from 2015-2016 that allegedly demonstrated Morgan’s bias toward Muslims. Manookian is not Muslim but claimed that his wife was Muslim and that his children were being raised in a Muslim household. Morgan responded that the tweets were political in nature and related to the 2015–2016 presidential campaign; he disavowed any knowledge of the religious faith and practices of Manookian’s family. The Board moved for Morgan to withdraw as Board counsel in the appeal, which the court allowed. A week later, Garrett, the Board’s Chief Disciplinary Counsel, told Morgan that his employment would be terminated. Several months later, Garrett notified Morgan that the Board had opened a disciplinary file against him. The matter was later dismissed.The Sixth Circuit affirmed the dismissal of Morgan’s 42 U.S.C. 1983 claims against the Board for lack of subject-matter jurisdiction based on Eleventh Amendment sovereign immunity but reversed the dismissal of the claim for damages against Garrett based on absolute quasi-judicial immunity. Extending judicial immunity here would extend its reach to areas previously denied— administrative acts like hiring and firing employees. View "Morgan v. Board of Professional Responsibility of the Supreme Court of Tennessee" on Justia Law

Harris went to the store, argued with a clerk, left the store, and entered the laundromat next door where his friend, Henderson, worked. Harris asserts that while he was between the buildings, the clerk came out, pointed a gun, and taunted him with racial slurs. Following Harris’s 911 call, four officers arrived. As shown on bodycams, they expressed disbelief in Harris’s report. The store clerk denied having a gun. The store had at least three surveillance cameras but the officers watched footage from only the front door, although Harris had reported that the incident occurred near the back door. Harris wanted to move forward with his report, believing the footage would corroborate his account. The officers indicated that the video revealed Harris had lied and arrested Harris. No officer took Henderson’s statement. Detective Busch reviewed the police report and passed it to the prosecutor for charging.Harris spent 18 days in jail before being released on bond. Weeks later, the state dropped Harris’s false felony report charge; the store clerks failed to appear. Harris sued the City of Saginaw, the officers, and Busch. The Sixth Circuit affirmed the denial of qualified immunity summary judgment to the officers, the grant of qualified immunity to Busch, and the dismissal of Harris’s failure-to-train and failure-to-supervise claims against the city. There is a genuine dispute of material fact regarding whether the officers arrested Harris without probable cause. View "Harris v. City of Saginaw, Michigan" on Justia Law

M.Q., a student attending public school in Knox County, Tennessee, was diagnosed with autism. M.Q. is largely nonverbal and has developmental delays in communication skills, social/emotional behavior, and pre-vocational skills. A suit under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400, Section 504 of the Rehabilitation Act, 29 U.S.C. 794; and Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101, alleged that M.Q. was improperly excluded from the general education classroom setting and placed him in a self-contained classroom for students with disabilities for nearly all his kindergarten academic instruction.The district court held that this placement violated the IDEA but rejected claims that also it also violated Section 504 and the ADA. The Sixth Circuit affirmed. The district court correctly found that the district complied with the statutory requirements with respect to including a general education teacher on M.Q.’s individual education plan (IEP) team— albeit under their most literal interpretation. The IEP cannot stand because it placed M.Q. in a more restrictive educational setting than his disability required. View "Knox County, Tennessee v. M.Q." on Justia Law

Moss purchased cocaine from a DEA informant and was charged with possession with intent to deliver 1,000 or more grams of cocaine and possession of a firearm during the commission of a felony. Moss’s first attorney moved for an entrapment hearing. Steingold then began representing Moss. At the entrapment hearing, 10 days later, Steingold attested to minimal pre-trial preparation. Moss was the only witness he presented. Steingold requested a continuance to contact witnesses he learned about during Moss’s direct and cross-examination. The court permitted Steingold to contact one witness but denied a continuance. The prosecution presented five witnesses and multiple exhibits. The court denied Moss’s motion to dismiss based on entrapment.At trial, Steingold waived his opening argument, presented no witnesses, and stipulated to the admission of the transcript from the entrapment hearing as substantive evidence. For one of the government’s two witnesses, Steingold did not object during his testimony or conduct any cross-examination. Steingold waived his closing argument. On appeal, Moss unsuccessfully argued that Steingold provided constitutionally ineffective assistance by waiving Moss’s right to a jury trial and stipulating to the admission of the evidence from the entrapment hearing.The Sixth Circuit reversed the district court’s order of habeas relief. The state court’s denial of Moss’s ineffective assistance claims under Strickland was not contrary to nor an unreasonable application of clearly established federal law. View "Moss v. Miniard" on Justia Law

Smucker’s is a federal contractor that supplies food items to the federal government. In 2021, by Executive Order, President Biden directed all federal contractors to “ensure that all [their] employees [were] fully vaccinated for COVID-19,” unless such employees were “legally entitled” to health or religious accommodations. The order made contractors “responsible for considering, and dispositioning, such requests for accommodations.” In September 2021, Smucker’s notified its U.S. employees that it would “ask and expect” them to “be fully vaccinated.” A month later, in the face of “deadlines in the federal order,” Smucker’s announced a formal vaccine mandate with exemptions based on “sincerely held religious beliefs.”The plaintiffs unsuccessfully sought religious exemptions, then sued Smucker's under the First Amendment's free-exercise guarantee. The Sixth Circuit affirmed the dismissal of the suit. When Smucker’s denied the exemption requests, it was not a state actor. Smucker’s does not perform a traditional, exclusive public function; it has not acted jointly with the government or entwined itself with it; and the government did not compel it to deny anyone an exemption. That Smucker’s acted in compliance with federal law and that Smucker’s served as a federal contractor, do not by themselves make the company a government actor. View "Ciraci v. J.M. Smucker Co." on Justia Law

Based on nominations, UC awarded “triumph cords” to graduating students who had overcome adversity. UC did not vet the nominees and unintentionally awarded a cord to a convicted sex offender. Goldblum, UC’s Title IX coordinator, told her supervisor, Marshall, that she would investigate how UC evaluated admissions applications from convicted sex offenders and address the controversy in the student newspaper. Goldblum forwarded a letter to Marshall, who ordered Goldblum not to submit anything until Marshall coordinated with other University officials. The administration had authorized Dean Petren to address the controversy. Marshall told Goldblum that Petren would issue UC’s response. Marshall also identified problems with the letter’s content. Goldblum texted Marshall that she intended to submit the letter and accept “any repercussions.” Marshall texted: “Please do not send.” Goldblum sent the letter, which was never published. Marshall reported Goldblum’s insubordination. During an investigation, UC discovered additional infractions: Goldblum repeatedly ignored Title IX complaints, criticized her colleagues in front of her staff, and missed reporting deadlines. UC allowed Goldblum to resign in lieu of termination.Goldblum sued UC for unlawful termination under Title VII and Title IX. The Sixth Circuit affirmed the dismissal of the claims. UC had legitimate nonretaliatory reasons to fire Goldblum, who has not produced “sufficient evidence from which a jury could reasonably reject” UC’s proffered reasons. Her letter was not “protected activity.” No reasonable juror could conclude that UC’s work-performance rationale was not based in fact. View "Goldblum v. University of Cincinnati" on Justia Law