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

A man walking along the shoulder of a Nashville interstate was approached by a state trooper, who intended to pat him down and offer a ride. During the encounter, the man produced a box cutter, failed to comply with repeated police commands, and a standoff ensued involving multiple officers from different agencies. After about thirty-five minutes, the man took two quick steps toward the officers, pulled an object from his pocket, and pointed it at them in a manner resembling a firearm. In response, nine officers fired approximately thirty-three shots, twelve of which struck and killed him. Notably, after the man had fallen to the ground and appeared incapacitated, one officer fired two additional shots.The decedent’s wife filed suit in the United States District Court for the Middle District of Tennessee against the involved cities and officers, alleging excessive force in violation of the Fourth Amendment. The officers moved to dismiss the complaint on the basis of qualified immunity. The district court denied the motions, finding that the complaint plausibly alleged a constitutional violation and that the right at issue was clearly established. The court also determined that video evidence did not blatantly contradict the plaintiff’s allegations regarding the officers’ conduct after the man was incapacitated.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that eight of the nine officers were entitled to qualified immunity because their initial use of deadly force was objectively reasonable under the circumstances. However, the court found that the officer who fired two shots after the man was incapacitated was not entitled to qualified immunity at this stage, as the complaint plausibly alleged a violation of clearly established law prohibiting the use of force against a neutralized suspect. The court affirmed in part and reversed in part. View "Eastep v. City of Nashville" on Justia Law

Five University of Kentucky football players attended a fraternity party where they were subjected to racial slurs and, in some cases, physical assault by attendees. After the incident, a fraternity member called the police and accused the players of assault and burglary, claiming they brandished weapons. Detective Cory Vinlove led the investigation and, despite evidence suggesting the players were victims, allegedly fabricated information to support criminal charges against them. The university cleared the players of wrongdoing, but Vinlove proceeded with charges, and a police press release publicized the allegations. Ultimately, a grand jury declined to indict the players, but the negative publicity had already damaged their reputations and careers.The players filed lawsuits in the United States District Court for the Eastern District of Kentucky against Vinlove, Sergeant Donnell Gordon, Police Chief Lawrence Weathers, and the Lexington-Fayette Urban County Government, asserting federal claims under 42 U.S.C. § 1983 (including malicious prosecution and fabrication of evidence) and various state-law claims. The district court consolidated the cases and granted the defendants’ motion to dismiss all claims except a state-law malicious prosecution claim against Vinlove. The court found that the plaintiffs had not alleged a deprivation of liberty under the Fourth Amendment, as required for their federal claims, and that the state-law claims were inadequately pled. The court later dismissed the remaining state-law claim for lack of subject matter jurisdiction.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the plaintiffs failed to allege a deprivation of liberty under the Fourth Amendment, as they were not arrested, detained, or subject to pretrial restrictions. The court also held that the press release was absolutely privileged under Kentucky law, defeating the defamation claim, and that the plaintiffs did not sufficiently allege that Gordon or Weathers initiated or continued the prosecution, defeating the state-law malicious prosecution claim. View "Adams v. Lexington-Fayette Urban County Gov't" on Justia Law

A prisoner at a Michigan correctional facility was involved in a physical altercation with another inmate, after which he was subdued and handcuffed by corrections officers. Two officers then escorted him through a hallway and into a prison yard. Upon entering the yard, the officers performed a takedown maneuver, throwing the prisoner to the ground and fracturing his foot. The prisoner claimed he did not resist or act aggressively before the takedown, while the officers asserted that he had lunged away, prompting their response. Surveillance footage captured much of the incident, but some key moments were obscured or unclear. The prisoner suffered significant injury as a result of the takedown.Following the incident, a prison misconduct hearing was held, and the hearing officer found the prisoner guilty of assaulting staff, relying heavily on the video evidence, which the prisoner was not permitted to view. The prisoner did not seek judicial review of this administrative finding. He then filed a lawsuit in the United States District Court for the Eastern District of Michigan under 42 U.S.C. § 1983, alleging excessive force in violation of the Eighth Amendment. The district court granted summary judgment to the officers, holding they were entitled to qualified immunity. The court reasoned that the hearing officer’s factual findings should have preclusive effect and that the video evidence clearly contradicted the prisoner’s account.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court’s decision. The appellate court held that the hearing officer’s findings should not have preclusive effect because the prisoner lacked a full and fair opportunity to litigate the facts, particularly due to his inability to access crucial evidence. The court also found that the video evidence did not so clearly contradict the prisoner’s version as to warrant summary judgment. The court concluded that there was a genuine dispute of material fact regarding whether the officers used excessive force, and that the officers had forfeited the “clearly established” prong of their qualified immunity defense. The case was remanded for further proceedings. View "Nash v. Bryce" on Justia Law

A married couple, both employees of UT-Battelle, objected to their employer’s COVID-19 vaccine mandate on religious grounds, specifically because of their belief that the vaccines’ development involved the use of fetal cell lines from abortions, which conflicted with their Christian faith. UT-Battelle required employees seeking religious exemptions to undergo a panel interview and read a “fact sheet” presenting religious leaders’ support for vaccination. Employees granted religious accommodations were placed on unpaid leave, while those with medical accommodations were not. Mrs. Bilyeu ultimately received a medical exemption before the policy took effect and did not lose pay or work time. Mr. Bilyeu, however, was placed on unpaid leave after exhausting his vacation days, returning to work only after the policy was rescinded.The United States District Court for the Eastern District of Tennessee granted summary judgment to UT-Battelle on all claims except Mrs. Bilyeu’s retaliation claim, which was later settled. The court found that Mrs. Bilyeu lacked standing and that Mr. Bilyeu had not suffered a materially adverse employment action under Title VII.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment as to Mrs. Bilyeu, holding she lacked Article III standing because she suffered no cognizable injury after receiving her medical accommodation. For Mr. Bilyeu, the Sixth Circuit vacated the summary judgment on his disparate treatment and failure-to-accommodate claims, instructing the district court to reconsider them in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, which eliminated the “materially adverse” requirement for adverse employment actions under Title VII. The court reversed the summary judgment on Mr. Bilyeu’s retaliation claim, finding sufficient evidence for a reasonable jury to conclude that the interview process could dissuade a reasonable worker from seeking a religious accommodation, and remanded for further proceedings. View "Bilyeu v. UT-Battelle, LLC" on Justia Law

Two African American truck drivers employed by a large transportation company in Nashville alleged that their supervisors subjected them to a racially hostile work environment. The plaintiffs claimed they were assigned longer routes and more hours than their non-African American colleagues for the same pay, denied certain benefits, and given older or more damaged trucks. They also testified that their supervisors, one of whom was also African American, repeatedly called them “monkey” and “monkey ass,” used demeaning language, and threatened or criticized them in ways not directed at white coworkers. The plaintiffs reported this conduct to company liaisons and managers, but the alleged harassment continued. One plaintiff resigned due to the conditions, while the other was terminated for alleged performance issues, which he disputed.The United States District Court for the Middle District of Tennessee granted summary judgment to the employer, finding that the plaintiffs had not provided sufficient evidence of race-based harassment to support a hostile work environment claim. The court reasoned that the terms used by the supervisors were not inherently racist, that the plaintiffs had not shown the terms were used only against African Americans, and that the plaintiffs’ comparative evidence was insufficient because it did not establish the race of the relevant comparators with the required specificity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the grant of summary judgment de novo. The appellate court held that the plaintiffs’ testimony regarding the use of “monkey” and “monkey ass” by supervisors constituted evidence of race-based harassment, given the well-established history of those terms as racial slurs against African Americans. The court also found that the plaintiffs’ comparative and other evidence was admissible and sufficient to raise genuine issues of material fact regarding the severity and pervasiveness of the harassment and the employer’s liability. The Sixth Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Smith v. P.A.M. Transport, Inc." on Justia Law

A sheriff’s deputy responded to a 911 call reporting a domestic dispute at a residence, with allegations that the homeowner had threatened a woman with a gun and grabbed her by the neck. Upon arrival, the deputy encountered three women and a small child outside or in the garage; none appeared injured or in distress. The homeowner stood in the garage doorway, raised his hands when ordered, and denied wrongdoing. When the deputy attempted to handcuff him, the homeowner retreated into his house, resisted being handcuffed, and a physical altercation ensued, during which the deputy punched the homeowner. The deputy ceased his efforts after being told that no gun threat had occurred.The homeowner filed suit under 42 U.S.C. § 1983 in the United States District Court for the Middle District of Tennessee, alleging unlawful entry and excessive force in violation of the Fourth Amendment. Both parties moved for summary judgment. The district court denied summary judgment to the deputy on the unlawful entry and excessive force claims, finding that material factual disputes existed as to whether exigent circumstances justified the warrantless entry and whether the force used was reasonable. The deputy appealed, asserting entitlement to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that, viewing the facts in the light most favorable to the plaintiff, a reasonable jury could find that the deputy lacked an objectively reasonable basis for believing exigent circumstances existed to justify a warrantless entry. The court further held that the right to be free from such entry and from force used to effectuate it was clearly established. Because the deputy failed to argue that his use of force was reasonable even if the entry was unlawful, the court affirmed the district court’s denial of summary judgment on both claims. View "Hoover v. Due" on Justia Law

A woman experiencing a mental health crisis called 911 and requested that police come to her home to shoot her. Three officers responded and found her holding a bat and a pickaxe. The officers maintained a distance of about fifteen feet and attempted to de-escalate the situation, with one officer assuring her that she would not be harmed. After several minutes, and following an interaction with the woman’s mother, one officer tased her, and another officer shot her multiple times as she moved in the direction of the officers. The woman survived but suffered severe injuries.The plaintiff, acting on the woman’s behalf, filed suit in the United States District Court for the Middle District of Tennessee against the two officers and the Metropolitan Government of Nashville and Davidson County under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment, and also brought a negligence claim against the municipality. The officers moved to dismiss the complaint on qualified immunity grounds, and the municipality sought judgment on the pleadings. The district court granted the officers’ motion to dismiss the excessive force claims and the municipality’s motion on the negligence claim, but initially denied the municipality’s motion as to the § 1983 claim. Later, the district court granted the municipality’s motion for judgment on the pleadings on the § 1983 claim as well.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the complaint plausibly alleged that both officers violated the woman’s clearly established Fourth Amendment rights by tasing and shooting her under the circumstances described. The court also held that the district court erred in dismissing the municipal liability claim. Accordingly, the Sixth Circuit reversed the dismissal of the claims against the officers, vacated the judgment for the municipality, and remanded for further proceedings. View "Chrestman v. Metropolitan Government of Nashville and Davidson County" on Justia Law

A tenured English professor at a public university in Ohio, who identifies as transgender, became involved in discussions about leading the university’s Center for the Study of Gender and Sexuality during a period of departmental restructuring. Although the professor expressed interest in directing the Center and was considered a strong candidate, the position was not open as the Center had gone dormant. The professor was offered a partial teaching load reallocation to help develop a new gender-studies major, but after a series of profanity-laden and disparaging social media posts targeting colleagues and administrators, the offer was rescinded. The professor also sought a tenure transfer to the main campus, which was denied by faculty committees after considering collegiality and departmental needs, with no discussion of gender identity.The United States District Court for the Northern District of Ohio granted summary judgment for the university and individual defendants on all claims. The court found no genuine dispute of material fact and concluded that the university’s actions were based on legitimate, nondiscriminatory reasons, including the professor’s unprofessional conduct and the department’s academic requirements. The professor appealed, challenging the district court’s rulings on claims of sex discrimination and retaliation under Title VII, First Amendment retaliation under 42 U.S.C. § 1983, and perceived-disability discrimination under the Rehabilitation Act.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s summary judgment. The court held that there was no direct or circumstantial evidence of discrimination or retaliation, that the professor’s social media posts did not constitute protected speech on matters of public concern under the First Amendment, and that there was insufficient evidence to support a perceived-disability claim. The court clarified that adverse employment actions under Title VII need only cause some harm, but found the university’s reasons for its decisions were not pretextual. View "GPat Patterson v. Kent State University" on Justia Law

Ulysses Feagin was involved in a police encounter after driving erratically, nearly causing a collision with a marked police cruiser, and subsequently leading officers on a brief pursuit. Upon stopping in a parking lot, Feagin ignored repeated commands to exit his vehicle, rolled up the windows, and appeared to reach toward the center console. When officers attempted to remove him, bullets fell from his pocket, and he physically resisted their efforts. Officer Moore deployed a taser to subdue Feagin, who was then handcuffed and placed in a police cruiser. While detained, Feagin continued to resist by kicking the cruiser’s window, prompting Moore to use pepper spray. A subsequent search of Feagin’s vehicle revealed drugs and firearms, leading to his conviction on multiple charges.The United States District Court for the Northern District of Ohio granted summary judgment to the defendants on most claims but denied it on two: Feagin’s excessive force claim related to the use of a taser and his deliberate indifference claim regarding medical care after being pepper sprayed. The district court found a genuine dispute over whether Feagin’s resistance was active or passive at the time of the tasing, but granted summary judgment on the pepper spray claim, citing Feagin’s continued resistance. The deliberate indifference claim was set for trial because defendants had not moved for summary judgment on that issue.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The Sixth Circuit reversed the denial of qualified immunity for the excessive force claim, holding that Officer Moore’s use of a taser was reasonable under the circumstances and did not violate clearly established law. The court dismissed the appeal regarding the deliberate indifference claim for lack of jurisdiction, as the issue had not been raised below, and remanded the case for further proceedings. View "Feagin v. Mansfield Police Dep't" on Justia Law

Christina Henry, a Licensed Practical Nurse at Southern Ohio Medical Center (SOMC), refused to comply with SOMC’s COVID-19 policy requiring either vaccination or weekly nasopharyngeal testing, citing religious objections. SOMC granted her a religious exemption from vaccination but denied her request for an exemption from all forms of COVID testing. Henry maintained that her religious beliefs prohibited her from undergoing any COVID test, including non-invasive methods, and proposed self-screening as an alternative. After continued refusal to test or vaccinate, SOMC placed her on unpaid leave. Henry did not request alternative testing methods during her leave and later declined to return to SOMC after the testing requirement was lifted.The United States District Court for the Southern District of Ohio granted summary judgment in favor of SOMC. The court found that Henry’s communications to SOMC indicated she sought exemption from all COVID testing, not just nasopharyngeal testing. It held that accommodating her request would impose an undue hardship on SOMC by endangering vulnerable patient populations. The court also determined that even if Henry had requested saliva testing, this would still constitute an undue hardship due to delays in obtaining test results and reduced effectiveness. Additionally, the court found that Henry failed to show SOMC’s stated reasons for placing her on unpaid leave were pretextual.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that Henry did not provide sufficient notice to SOMC of a limited objection to only certain types of testing and that either exempting her from all testing or providing saliva testing would impose an undue hardship on SOMC. The court also held that Henry failed to establish pretext in her retaliation claim. View "Henry v. Southern Ohio Medical Center" on Justia Law