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

Meng Huang, a former Ph.D. student at The Ohio State University (OSU), alleged that her advisor, Professor Giorgio Rizzoni, sexually harassed and assaulted her during her studies. Huang filed a lawsuit against OSU and Rizzoni, claiming Title VII quid pro quo sexual harassment and retaliation against OSU, and a due process violation against Rizzoni under 42 U.S.C. § 1983.The United States District Court for the Southern District of Ohio granted summary judgment to OSU on Huang’s Title VII claims, concluding she was not an "employee" under Title VII until August 2017. The court also ruled that Huang’s retaliation claim failed because her first protected activity occurred after the alleged adverse actions. Huang’s § 1983 claim against Rizzoni proceeded to trial, where the court trifurcated the trial and excluded evidence of Rizzoni’s alleged manipulation and coercion. The jury found in favor of Rizzoni.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the district court erred in determining Huang was not an employee under Title VII before August 2017, as her research work and the control Rizzoni exerted over her indicated an employment relationship. The court also held that Huang’s resistance to Rizzoni’s advances constituted protected activity under Title VII, and she presented sufficient evidence of adverse employment actions linked to her resistance.The Sixth Circuit reversed the district court’s summary judgment on Huang’s Title VII claims, vacated the trial verdict in favor of Rizzoni on the § 1983 claim, and remanded for a new trial. The court emphasized that the district court’s exclusion of relevant evidence regarding Rizzoni’s power and manipulation was an abuse of discretion, which prejudiced Huang’s ability to present her case. View "Huang v. Ohio State University" on Justia Law

Victor S. Couzens, the senior pastor of Inspirational Bible Church (IBC), faced a significant decline in church membership and financial troubles following public accusations of an adulterous relationship. In response, church leaders organized a vote to remove him from his position. To enforce this decision, they hired off-duty police officers for the next Sunday service. When Couzens attempted to address the congregation, the officers threatened him with arrest, leading him to leave the church. Couzens subsequently sued the officers, their police chief, and the City of Forest Park, alleging a conspiracy to deny him his constitutional rights.The United States District Court for the Southern District of Ohio granted summary judgment in favor of the defendants. The court found that while the officers' actions could be seen as a seizure under the Fourth Amendment, their actions were not unreasonable. The court also determined that the free exercise claim failed because the police department's policy did not target religious conduct. Without constitutional violations from individual defendants, the court found no merit in the municipal liability and civil conspiracy claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the officers' actions were objectively reasonable given the circumstances and the evidence they had, including a letter indicating Couzens' removal as pastor. The court also found that Couzens failed to establish a violation of his First Amendment rights, as the officers' actions did not reflect state interference in church governance. Consequently, the court upheld the summary judgment on the constitutional, civil conspiracy, and municipal liability claims. View "Couzens v. City of Forest Park, Ohio" on Justia Law

Two young African American boys died in a house fire after two City of Flint firefighters failed to properly search the home. The then-City Fire Chief, Raymond Barton, attempted to discharge the firefighters for gross misconduct. However, Flint’s Mayor, Sheldon Neeley, allegedly intervened to cover up the firefighters' actions to gain support from the firefighters’ union for his re-election. When Barton refused to comply with Neeley’s directives to alter official reports and make false public statements, Neeley fired him.In the United States District Court for the Eastern District of Michigan, Barton filed a lawsuit claiming that his termination was retaliation in violation of his First Amendment rights. The district court denied Neeley’s motion to dismiss based on qualified immunity, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Barton plausibly alleged a violation of his First Amendment rights, as public employees cannot be compelled to make false, politically motivated statements on matters of public concern in response to threats of retaliation. The court affirmed the district court’s denial of qualified immunity to Neeley, concluding that Barton’s refusal to alter reports and make false statements was protected speech, and that it was clearly established that such compelled speech and retaliation violated the First Amendment. View "Barton v. Neeley" on Justia Law

Alvin Moore, a Black man, worked at Coca-Cola Bottling Company (CCBC) from 2015 to 2018. In March 2017, after a workplace accident, Moore tested positive for marijuana at a level below the company's threshold. Despite this, he signed a Second Chance Agreement (SCA) requiring random drug testing for 24 months. In June 2017, Moore was fired for insubordination but was reinstated under a Last Chance Agreement (LCA), which he signed under pressure. In 2018, Moore tested positive for marijuana again and was terminated. He sued CCBC for racial discrimination and retaliation under Title VII and Ohio law.The United States District Court for the Southern District of Ohio granted summary judgment in favor of CCBC, finding that Moore had waived his pre-LCA claims by signing the LCA and failed to establish that CCBC's reasons for his termination were pretextual. The court presumed Moore had made a prima facie case for racial discrimination and retaliation but concluded that Moore did not show that CCBC's reasons for his termination were a pretext for discrimination.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court found that there was a genuine dispute of material fact regarding whether Moore voluntarily waived his pre-LCA claims by signing the LCA. The court noted that Moore's union representative had advised him to sign the LCA, suggesting he could still pursue his claims. The court also found that Moore had shown enough evidence to suggest that CCBC's reasons for his termination could be pretextual, particularly in light of the different treatment of similarly situated white employees.The Sixth Circuit reversed the district court's summary judgment and remanded the case for further proceedings, allowing Moore to pursue his claims of racial discrimination and retaliation. View "Moore v. Coca-Cola Consolidated, Inc." on Justia Law

Wade Jones was incarcerated at the Kent County Correctional Facility for five days in April 2018. During his incarceration, he experienced severe alcohol withdrawal symptoms. Despite being placed on an alcohol-withdrawal protocol, Jones did not receive timely or adequate medical care. On April 27, 2018, Jones went into cardiac arrest and was later transferred to a hospital, where he died a week later. His estate sued Kent County and several nurses, alleging deliberate indifference to his medical needs.The United States District Court for the Western District of Michigan held a trial where a jury found that nurses Melissa Furnace, Chad Goetterman, and James Mollo were deliberately indifferent to Jones’s medical condition, which was a proximate cause of his death. The jury awarded Jones’s estate $6.4 million in compensatory damages. The defendants moved for judgment as a matter of law or a new trial, arguing that the jury’s verdict was inconsistent, that no reasonable jury could find proximate cause, that the estate’s counsel engaged in misconduct, and that a juror’s failure to disclose his criminal history warranted a new trial. The district court denied these motions.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the defendants had forfeited their inconsistent-verdict argument by not objecting before the jury was discharged. It also found sufficient evidence to support the jury’s finding of proximate cause, noting that the jury could reasonably conclude that the nurses’ failure to provide timely medical care significantly decreased Jones’s likelihood of survival. The court further held that the estate’s counsel’s emotional display during trial did not constitute contumacious conduct warranting a new trial. Lastly, the court found no basis for a new trial due to juror misconduct, as the juror was never directly asked about his own criminal history during voir dire. View "Jones v. Kent County" on Justia Law

In January 2019, Ashley Franklin, an inmate at the Franklin County Regional Jail, was transported to a hospital by Jail Sergeant Brandon Price due to illness. During the transport, Price sexually assaulted Franklin. Franklin filed a lawsuit against Price, Franklin County, and two other Jail employees, asserting constitutional claims under 42 U.S.C. § 1983 and related state law claims. She alleged that Price and his superior, Captain Wes Culbertson, were deliberately indifferent to her safety and that Franklin County had inadequate policies and training to prevent such assaults.The United States District Court for the Eastern District of Kentucky granted Franklin’s motion for summary judgment on her Eighth Amendment claim against Price but denied her other claims. The court granted summary judgment in favor of the other defendants, finding no evidence that Culbertson or Franklin County were deliberately indifferent or that the County’s policies were inadequate. The court also found that the County’s previous incidents of misconduct did not establish a pattern of unconstitutional behavior. Franklin’s negligence claims against Culbertson and Jailer Rick Rogers were dismissed, with the court ruling that they were entitled to qualified immunity under Kentucky law.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Franklin County was not liable under § 1983 because Franklin failed to show a direct causal link between the County’s policies and her assault. The court also found that Culbertson and Rogers were entitled to qualified immunity, as their actions were discretionary and performed in good faith. Franklin’s claims of gross negligence were deemed forfeited due to lack of development in her arguments. The court concluded that Franklin had not established that the County’s policies or training were constitutionally inadequate or that there was a pattern of similar constitutional violations. View "Franklin v. Franklin County" on Justia Law

In 1974, Regina Andrews was found murdered, and her husband, Isaiah Andrews, was convicted of the crime based on circumstantial evidence. After nearly 46 years in prison, Isaiah was granted a new trial in 2020 when it was discovered that exculpatory evidence had been withheld. A new jury acquitted him in 2021. Subsequently, Isaiah filed a § 1983 lawsuit against the City of Cleveland and several officers, alleging violations of his Fourteenth Amendment rights due to the suppression of exculpatory evidence.The United States District Court for the Northern District of Ohio dismissed Isaiah's claims against the estates of the deceased officers, William Hubbard and Ernest Rowell, citing that the claims were filed too late under Ohio law. The court also granted summary judgment in favor of the City of Cleveland, concluding that the police did not withhold exculpatory evidence from the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of claims against the estates of Hubbard and Rowell, agreeing that Isaiah's claims were untimely under Ohio law. However, the court reversed the summary judgment in favor of the City of Cleveland. The appellate court found that there was a material dispute of fact regarding whether the police had withheld a crucial page of a police report linking another suspect to the crime scene. The court remanded the case to the district court to determine whether a City policy caused the alleged Brady violation. View "Estate of Andrews v. City of Cleveland" on Justia Law

In 1984, Richard Wershe, Jr., at fourteen, was recruited by the FBI as a drug informant. Over the next few years, he was involved in dangerous drug operations under the direction of federal and state officers. In 1987, Wershe was arrested and convicted of possessing a large quantity of cocaine, receiving a life sentence without parole, which was later amended to allow parole eligibility. While incarcerated, he cooperated with law enforcement in various investigations, including "Operation Backbone" and a grand jury against the "Best Friends" gang, based on promises of assistance with his parole. Despite his cooperation, Wershe was denied parole in 2003 and was only released in 2017, subsequently serving time in Florida for an unrelated charge until his release in 2020.Wershe filed two lawsuits: one in July 2021 against the City of Detroit and various federal and state officials under 42 U.S.C. § 1983 and Bivens, and another in October 2022 against the United States under the Federal Tort Claims Act (FTCA). He alleged constitutional violations and tort claims related to his time as a juvenile informant and subsequent parole denial. The United States District Court for the Eastern District of Michigan dismissed both lawsuits with prejudice, ruling that Wershe’s claims were time-barred and not subject to equitable tolling.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's dismissal. The court held that Wershe’s claims were indeed time-barred under the applicable statutes of limitations and that he was not entitled to equitable tolling. The court found that Wershe had constructive knowledge of the filing deadlines, did not diligently pursue his claims, and that the defendants would be prejudiced by the delay. Additionally, the court ruled that the district court did not err in dismissing the complaints with prejudice or in its handling of materials outside the pleadings. View "Wershe v. City of Detroit" on Justia Law

Jane Doe, a student in a dual enrollment program with the University of Kentucky, reported being raped by John Doe (JD) in her dorm room. The University held four student conduct hearings. The first three hearings resulted in JD's expulsion or suspension, but each decision was overturned by the University’s appeals board due to procedural errors. After the third reversal, Doe filed a Title IX lawsuit against the University. In the fourth hearing, the panel ruled against her, and Doe claimed the University mishandled this hearing in retaliation for her lawsuit.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the University, concluding that Doe could not establish a prima facie case of retaliation under Title IX. The court found that Doe was no longer a student at the time of the fourth hearing and thus could not claim adverse school-related actions. It also limited its analysis to the allegations in Doe’s complaint, excluding additional evidence presented in opposition to summary judgment.The United States Court of Appeals for the Sixth Circuit reversed and remanded the case. The court held that Doe could suffer adverse school-related actions even if she was not a current student and that the University’s disciplinary proceedings are educational programs under Title IX. The court found that the University’s delays, procedural errors, and failure to adequately prosecute JD could dissuade a reasonable person from pursuing a Title IX claim. The court also held that Doe presented sufficient evidence to establish a causal connection between her lawsuit and the adverse actions. The case was remanded for further proceedings consistent with this opinion. View "Doe v. University of Kentucky" on Justia Law

Dominique Ramsey and Travis Sammons were incarcerated for over five years for the murder of Humberto Casas. Their convictions were overturned by Michigan appellate courts due to an improper identification, leading to the dismissal of the case and their release. Ramsey and Sammons then sued David Rivard, a Michigan State Police sergeant, under federal and state law for malicious prosecution, fabrication of evidence, and unduly suggestive identification. The district court denied Rivard’s motion for summary judgment, rejecting his claims of absolute and qualified immunity for the federal claims and governmental immunity for the state law claim. Rivard appealed.The United States District Court for the Eastern District of Michigan denied Rivard’s motion for summary judgment, finding that he was not entitled to absolute or qualified immunity for the federal claims nor to governmental immunity for the state law claim. The court determined that there were genuine disputes of material fact regarding Rivard’s conduct and the reliability of the identification procedure he oversaw. Rivard then appealed to the United States Court of Appeals for the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit dismissed Rivard’s appeal regarding the denial of qualified immunity for the federal malicious prosecution and fabrication of evidence claims due to lack of appellate jurisdiction. The court affirmed the district court’s denial of summary judgment on the remaining claims. The court held that Rivard was not entitled to absolute immunity for his pretrial conduct and that there were genuine disputes of material fact regarding his good faith, precluding summary judgment on the state law malicious prosecution claim. The court also found that a jury could determine the show-up identification was unduly suggestive and unreliable, thus violating clearly established law. View "Ramsey v. Rivard" on Justia Law