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

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

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law

A man seeking treatment for mental health issues voluntarily admitted himself to a hospital in Chattanooga, Tennessee. Medical staff determined he needed emergency medication and began to physically restrain him when he refused a shot. An off-duty police officer, working as a hospital security guard and wearing his police uniform, intervened. He twisted the patient's arm behind his back, and when the patient pulled away to relieve pain, the officer punched the patient’s head into a cinderblock wall, causing head trauma. The patient remained nonviolent throughout and was smaller in stature than those restraining him.Following the incident, the Chattanooga Police Department conducted an internal investigation. Opinions within the review process were divided, but the interim chief ultimately found no policy violation. The patient filed suit in the United States District Court for the Eastern District of Tennessee, alleging excessive force under 42 U.S.C. § 1983, multiple state-law torts, and municipal liability against the City for failing to train or supervise the officer. The district court granted summary judgment for the officer on all but the assault and battery claim, finding qualified immunity on the excessive force claim, and granted summary judgment for the City on all claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that, although a reasonable juror could find the officer’s use of force excessive under the circumstances, the law was not clearly established that an officer in this situation could not use such force. Therefore, the officer was entitled to qualified immunity. The court also found that the City was not liable under Monell since the plaintiff failed to demonstrate that a final policymaker’s actions were the moving force behind his injury. The district court’s judgment was affirmed. View "Guptill v. City of Chattanooga" on Justia Law

An attorney who chaired the Davidson County Election Commission was also employed at a law firm that represented the Metropolitan Government of Nashville and Davidson County. The Election Commission became involved in a dispute over whether a citizen-initiated tax-repeal referendum should be placed on the ballot, a measure opposed by the city government and certain city council members. The attorney, acting as commission chair, supported certifying the referendum. Following pressure from city officials, including a council member who threatened to withdraw city business from the law firm if the attorney continued supporting the referendum, the law firm terminated the attorney’s employment after he refused to change his position.The attorney filed suit in the United States District Court for the Middle District of Tennessee, asserting violations of his First Amendment rights under 42 U.S.C. § 1983, among other claims. The district court denied motions to dismiss based on qualified immunity filed by both the council member and the law firm. The court concluded that the council member’s alleged conduct violated clearly established First Amendment law and that the law firm, as a private entity, was not entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit determined that both the council member and the law firm were eligible to assert qualified immunity due to their public functions in this context. The court held that the council member was not entitled to qualified immunity because the complaint plausibly alleged he violated clearly established First Amendment rights by causing the attorney’s firing due to protected speech. However, the court found that the law firm was entitled to qualified immunity, as there was no clearly established law prohibiting a law firm from firing an employee in response to client pressure under these circumstances. Accordingly, the Sixth Circuit affirmed the denial of qualified immunity for the council member, reversed as to the law firm, and remanded for further proceedings. View "DeLanis v. Metropolitan Government of Nashville" on Justia Law