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

In January 2019, Detective Lori Russ searched Connie Reguli’s private Facebook records, allegedly due to Russ’s dislike of Reguli’s criticism of the police. Reguli discovered the search a year later while preparing for her criminal trial but did not sue at that time. In July 2022, during her sentencing, Russ seemed to admit that Reguli’s speech motivated the search. Reguli then filed a First Amendment retaliation claim against Russ and her employer in November 2022 under 42 U.S.C. § 1983.The United States District Court for the Middle District of Tennessee dismissed Reguli’s claim as untimely, reasoning that the claim accrued when Reguli learned of the search in January 2020, not when she learned of Russ’s motivation in July 2022. The court applied Tennessee’s one-year statute of limitations for § 1983 claims, concluding that Reguli’s lawsuit was filed too late.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that Reguli’s First Amendment retaliation claim accrued when she discovered the search in January 2020, as she knew of the injury and its cause at that time. The court rejected Reguli’s argument that the claim accrued only when she learned of Russ’s retaliatory motive, stating that the statute of limitations begins when the plaintiff knows or should know of the injury, not necessarily the motive behind it. The court also noted that Reguli did not renew her tolling argument on appeal, thus forfeiting it. View "Reguli v. Russ" on Justia Law

Marc Susselman received a traffic ticket from a Washtenaw County Sheriff’s deputy for failing to yield to a police cruiser with flashing lights. This ticket was later dismissed, but Susselman received another citation for failing to obey a police officer directing traffic. The Michigan circuit court ultimately dismissed the second ticket as well. Susselman then filed a federal lawsuit asserting constitutional and state law claims against Washtenaw County, the Washtenaw County Sheriff’s Office, the sheriff’s deputy, and Superior Township, Michigan.The United States District Court for the Eastern District of Michigan granted the defendants' motions to dismiss all claims. Susselman appealed the decision. The district court had found that the Washtenaw County Sheriff’s Office could not be sued under 42 U.S.C. § 1983 and that Susselman had waived certain state-law claims. The court also dismissed Susselman’s federal claims, including First Amendment retaliation and Fourteenth Amendment malicious prosecution, as well as state-law claims for malicious prosecution and intentional infliction of emotional distress.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that Susselman failed to plausibly allege a constitutional violation or behavior by the deputy that would support his claims. Specifically, the court found that the issuance of the second ticket did not constitute a violation of substantive due process or First Amendment rights. Additionally, the court determined that Susselman did not establish a civil conspiracy or meet the requirements for his state-law claims. The court also concluded that Susselman did not identify any municipal policy or custom that resulted in a constitutional violation, thus dismissing his claims against Washtenaw County and Superior Township. View "Susselman v. Washtenaw County Sheriff's Office" on Justia Law

In September 2018, Bryana Baker was arrested and taken to Butler County Jail, where she began experiencing drug withdrawal symptoms. After attempting to escape, she was placed in disciplinary isolation. Despite multiple mental health assessments indicating she was not suicidal, Baker was placed on suicide watch due to erratic behavior. On September 24, she was removed from suicide watch but was not cleared for single-celling. The next day, after a series of altercations with her cellmate, Officer April Riahi closed Baker’s cell door. Shortly thereafter, Baker was found hanging in her cell and later died.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants, including Officer Riahi, Sheriff Richard Jones, and Butler County. The court found no evidence of deliberate indifference or constitutional violations by the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that Officer Riahi was entitled to qualified immunity because no clearly established law indicated her actions were unconstitutional. The court also found that Sheriff Jones could not be held liable under supervisory liability since there was no underlying constitutional violation by Riahi. Additionally, the court ruled that Butler County was not liable under municipal liability theories because there was no deliberate indifference to a clearly established right. Lastly, the court determined that Riahi and Jones were entitled to Ohio statutory immunity on the state-law claims, as their actions did not amount to recklessness under Ohio law.The Sixth Circuit affirmed the district court’s judgment, granting summary judgment to the defendants on all claims. View "Campbell v. Riahi" on Justia Law

The case involves a challenge to Tennessee's policy of not allowing amendments to the sex listed on birth certificates based on gender identity. The plaintiffs, transgender individuals, argue that this policy violates their rights under the Equal Protection and Due Process Clauses of the Fourteenth Amendment. They seek a procedure that permits changes to the sex designation on birth certificates based on self-reported gender identity.The United States District Court for the Middle District of Tennessee dismissed the plaintiffs' claims. The court found that Tennessee's policy did not violate the Equal Protection Clause because it treated all individuals equally by requiring proof of an error to amend a birth certificate. The court also rejected the substantive due process claim, holding that there is no fundamental right to a birth certificate that reflects gender identity rather than biological sex.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court held that Tennessee's policy does not discriminate based on sex or transgender status and is subject to rational basis review. The policy was found to be rationally related to legitimate state interests, such as maintaining accurate and consistent vital records. The court also concluded that the plaintiffs did not have a substantive due process right to amend their birth certificates to reflect their gender identity, as such a right is not deeply rooted in the nation's history and tradition.The Sixth Circuit's main holding is that Tennessee's policy of not allowing amendments to the sex listed on birth certificates based on gender identity does not violate the Equal Protection or Due Process Clauses of the Fourteenth Amendment. The court emphasized that the Constitution does not require states to adopt the plaintiffs' preferred policy and that such decisions are best left to the democratic process. The court affirmed the district court's dismissal of the plaintiffs' claims. View "Gore v. Lee" on Justia Law

During the COVID-19 pandemic, Kalitta Air, LLC implemented a vaccine mandate for all its employees. Employees who could not receive a vaccination due to a disability or a sincerely held religious belief could request an accommodation and would be placed on unpaid leave. If they remained unvaccinated after the leave period, they could either voluntarily resign or be terminated. Eleven employees, including five pilots, sued Kalitta under Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act, claiming that the mandate discriminated against them based on their religious beliefs and/or disabled status.The district court found that the Railway Labor Act precluded it from hearing certain claims by the pilots, who were subject to a collective bargaining agreement. These claims had to first go through arbitration as minor disputes. The pilots appealed this decision.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the pilots' claims under Title VII and the Americans with Disabilities Act required interpretation of the collective bargaining agreement, and thus were minor disputes that had to be resolved through arbitration. The court also held that the pilots' claim of discrimination based on perceived disability would require interpretation of the collective bargaining agreement, and was therefore also precluded by the Railway Labor Act. View "Odell v. Kalitta Air, LLC" on Justia Law

The case involves a dispute between Wendell Shane Mackey, a local resident, and Jeff Rising, a real-estate agent who served one term as a part-time City Commissioner for Adrian, Michigan. Mackey posted information about Rising on Facebook that Rising believed to be false. Rising responded by calling Mackey’s mother and allegedly threatened to “hurt” Mackey if he did not delete the post. Mackey sued, arguing that Rising’s threat of physical violence violated the First Amendment because Rising made it in his capacity as a Commissioner to stifle Mackey’s speech.The United States District Court for the Eastern District of Michigan granted summary judgment to Rising, concluding that he had acted as a private citizen when he made the alleged threats. Mackey appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit affirmed the lower court's decision. The court found that Rising, as a legislator, did not have any “authority” to use (or threaten) physical force on behalf of the City of Adrian. His alleged “misuse” of the power, therefore, could not qualify as state action. The court also found that Rising’s acceptance of the City’s insurance for his defense did not conflict with his state-action defense on the merits, and thus, neither waiver nor judicial estoppel applied. View "Mackey v. Rising" on Justia Law

The case involves the Tennessee Conference of the National Association for the Advancement of Colored People (NAACP) challenging a state policy that requires some convicted felons to submit additional documentation to confirm their eligibility to vote. The NAACP argued that this policy violated the National Voter Registration Act (NVRA). A district court agreed with the NAACP and permanently enjoined the policy in the middle of the 2024 election cycle. Tennessee's Secretary of State and Coordinator of Elections appealed this decision and sought a stay of the injunction pending appeal.The district court's decision was based on the finding that the NAACP had standing to challenge the policy and that the policy violated the NVRA. The court held that the policy was unnecessary for determining the eligibility of those with felony convictions as the state had other information at its disposal to make that decision.The United States Court of Appeals for the Sixth Circuit granted the stay for two reasons. First, the injunction triggered the Supreme Court’s “Purcell principle,” which instructs federal courts not to disrupt state election rules close to an election. Second, the court found that the NAACP likely did not present enough evidence to prove its standing to challenge the Documentation Policy. The court concluded that the NAACP's claim that the policy forced it to divert its resources to help those convicted of felonies track down the records they need to register was not supported by specific facts. View "Tennessee Conference of the NAACP v. Lee" on Justia Law

The case involves Shannon Blick, a former principal of an elementary school in the Ann Arbor Public School District. In 2019, Blick was placed on paid leave while the school district investigated her role in a custodian's over-billing scheme. The leave lasted two years, and the school district eventually terminated Blick's contract. Blick filed a lawsuit while still on leave, alleging that various officials violated her freedoms of speech and association under the First Amendment. She also brought race-discrimination, due-process, and conspiracy claims against these officials. The district court rejected Blick's First Amendment claims at the summary-judgment stage and dismissed the other claims on the pleadings.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that Blick failed to show a reversible error. She argued that the school district violated the First Amendment by imposing a prior restraint that barred her from speaking during her leave and by taking harmful actions against her in retaliation for her speech. However, the court found that Blick's lawyers did not provide sufficient information about what she wanted to say or what she did say. The court also found that Blick's opening brief did not preserve her challenges to much of the district court's motion-to-dismiss decision. As a result, the court affirmed the district court's decision. View "Blick v. Ann Arbor Public School District" on Justia Law

The case involves Benjamin Stanley, who was employed by Western Michigan University (WMU) for about a month before his employment was terminated. Stanley, who has severe ADHD, claimed that WMU and certain supervisors discriminated and retaliated against him in violation of the Americans with Disabilities Act (ADA). He also brought a claim under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), as well as a claim for intentional infliction of emotional distress. The district court dismissed Stanley’s federal claims for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and dismissed his state-law claims for failure to comply with the Michigan Court of Claims Act’s notification statute.The district court's dismissal of Stanley's claims was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court’s dismissal of Stanley’s federal claims and the denial of Stanley’s motion for leave to amend his complaint. However, the court vacated the judgment in part and remanded to the district court to dismiss Stanley’s federal and state-law claims without prejudice. The court found that the district court lacked subject-matter jurisdiction to adjudicate Stanley’s ADA claims because the defendants were entitled to Eleventh Amendment immunity, and Stanley lacked standing to request injunctive relief from the individual defendants. The court also found that the district court lacked jurisdiction to decide Stanley’s state-law claims because it lacked subject matter jurisdiction over any federal issues. View "Stanley v. Western Michigan University" on Justia Law

A group of twenty states sued the U.S. Department of Education and other federal entities, challenging the Department's interpretation of Title IX to prohibit discrimination based on sexual orientation and gender identity in education programs receiving federal financial assistance. The states argued that the Department's interpretation, issued without undergoing the notice-and-comment process required for legislative rules under the Administrative Procedure Act (APA), was procedurally and substantively unlawful.The U.S. District Court for the Eastern District of Tennessee granted the states a preliminary injunction, halting the enforcement of the Department's interpretation. The Department appealed, arguing that the states lacked standing, the interpretation was unreviewable, and the district court abused its discretion in issuing the injunction.The U.S. Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the states had standing to sue, the Department's interpretation was reviewable, and the states were likely to succeed on their claim that the interpretation was a legislative rule that should have undergone the notice-and-comment process. The court also found that the states would likely suffer irreparable harm without the injunction, the balance of equities tipped in their favor, and the public interest favored the injunction. View "Tennessee v. Department of Education" on Justia Law