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

The case revolves around Yvonne Craddock, an African American woman who was terminated from her employment at FedEx Corporate Services following a workplace altercation. Craddock alleged that her termination was racially motivated, in violation of Title VII of the Civil Rights Act of 1964. The case was presented to a jury, which concluded that FedEx's reason for termination was pretextual, but that Craddock had failed to demonstrate that FedEx intentionally discriminated against her because of her race. Craddock appealed, arguing that the district court had made several errors, including forcing her to bifurcate the liability and damages portions of her trial and excluding testimony and evidence pertaining to events post-termination.The district court had granted FedEx’s motion to dismiss Craddock’s libel claim, Family Medical Leave Act claim, 42 U.S.C. § 1981 claim, and spoliation claim, but denied dismissal of her Title VII claims. After discovery, the court granted FedEx’s motion for summary judgment on Craddock’s Title VII claims. The case was then taken to the United States Court of Appeals for the Sixth Circuit.The Court of Appeals held that the district court did not abuse its discretion regarding the claims raised by Craddock, and affirmed the jury’s verdict. The court found that the district court's decision to bifurcate the trial was not an abuse of discretion, and that the court's exclusion of testimony and exhibits postdating the termination was not erroneous. The court also found no error in the district court's trial rulings and case management decisions, and concluded that the jury verdict form was not plainly erroneous. The court further held that the cumulative effect of the alleged errors did not deprive Craddock of a trial consistent with constitutional guarantees of due process. View "Craddock v. FedEx Corporate Services, Inc." on Justia Law

An inmate, Timothy Finley, who suffers from severe psychiatric disorders, was placed in a heavily restrictive cell in administrative segregation for approximately three months by prison officials. Finley brought a case against the deputy wardens, Erica Huss and Sarah Schroeder, alleging violations of the Eighth Amendment and his right to procedural due process, as well as disability-discrimination claims under the Americans with Disabilities Act and the Rehabilitation Act.The district court granted summary judgment to Huss and Schroeder on all claims. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision on Finley’s procedural due process and statutory discrimination claims. However, the court reversed the lower court's decision on Finley’s Eighth Amendment claim, finding that he presented sufficient evidence to find that the deputy wardens violated his clearly established rights. The court remanded the case for further proceedings on the Eighth Amendment claim. View "Finley v. Huss" on Justia Law

The case involves Brian Dewayne Darden-Mosby, who was convicted of two federal drug-dealing offenses. During the investigation, Drug Enforcement Agency (DEA) agents executed a search warrant for Darden-Mosby’s house and car, discovering an unregistered firearm, a money counter, drug ledgers, marijuana, and a backpack containing cocaine. They also seized $112,690 in cash found in various locations in his bedroom. After the search, police pulled over one of Darden-Mosby’s cocaine suppliers and found Darden-Mosby in the passenger seat with a bank envelope containing $2,500 in cash and two cashier’s checks totaling nearly $150,000.The United States prosecuted Darden-Mosby for various crimes based on the drugs and guns found in his house. As part of the prosecution, the government initiated criminal-forfeiture proceedings against the cash from Darden-Mosby’s bedroom, the two cashier’s checks, and the $2,500 found in Darden-Mosby’s pocket. Darden-Mosby sought to suppress the cashier’s checks and $2,500, arguing the detective’s search violated the Fourth Amendment. The district court denied the motion. The government ultimately opted not to introduce that evidence at trial, and it dismissed the criminal forfeiture claims against the two checks.A jury convicted Darden-Mosby of two drug-dealing offenses. The government declined to prosecute the forfeiture of the $2,500 in cash from the traffic stop any further but continued to pursue criminal forfeiture of the $112,690 from Darden-Mosby’s house. After a hearing and additional briefing, the court concluded the cash was connected to Darden-Mosby’s drug dealing and ordered the criminal forfeiture of the money.Separate from the government’s criminal-forfeiture actions, the DEA commenced administrative-forfeiture proceedings against the two cashier’s checks and the $2,500. These proceedings resulted in the administrative forfeiture of all three assets.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed in part and reversed in part. The court affirmed the district court’s criminal-forfeiture order with respect to the $92,470 found in the safe and shoebox at Darden-Mosby’s house but reversed with respect to the $20,220 found in and on the dresser. The court found that Darden-Mosby offered credible evidence that the $20,220 found on and in the dresser had legal sources and purposes. However, the court found that Darden-Mosby’s evidence was considerably weaker when it came to the $92,470 in the safe and shoebox. View "United States v. Darden-Mosby" on Justia Law

The case involves the family of Todd Kerchen, who died from a lethal dose of fentanyl. The family filed a complaint against the University of Michigan and Dr. James Woods, alleging violations under 42 U.S.C. § 1983 and Michigan state law. The family claimed that the fentanyl that killed Todd originated from a University of Michigan pharmacology lab where Christian Raphalides, the person who allegedly provided the drug to Todd, worked. The lab was overseen by Dr. Woods. The family argued that the lab's lax policies surrounding the use of controlled substances led to Todd's death.The district court denied the defendants' motion to dismiss and ordered limited discovery on whether the action was barred by the statutes of limitations applicable to the plaintiffs' claims. The defendants appealed this decision.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The court found that the University of Michigan and Dr. Woods in his official capacity were entitled to sovereign immunity, barring all claims against them. The court also found that Dr. Woods in his individual capacity was entitled to qualified immunity, barring the § 1983 claim against him. Furthermore, the court found that the wrongful death claim against Dr. Woods in his individual capacity should be dismissed as it was barred by governmental immunity. The court dismissed the remainder of the defendants' appeal for lack of jurisdiction. View "Kerchen v. University of Michigan" on Justia Law

This case involves a lawsuit filed by the family of Bill Heeter against Officer Kenneth Bowers and the Columbus Police Department. The family alleges that Officer Bowers used excessive force and violated Mr. Heeter's constitutional rights when he shot and killed Mr. Heeter during a police response to a suicide threat. The family also alleges that Officer Bowers violated Mr. Heeter's right to adequate medical care by failing to administer first aid after the shooting.The case was initially heard in the United States District Court for the Southern District of Ohio, where the defendants claimed immunity from the lawsuit. The district court granted the defendants immunity from some claims but denied others. The two constitutional claims against Officer Bowers that survived qualified immunity in the district court are the central focus of this appeal.The United States Court of Appeals for the Sixth Circuit affirmed the district court's denial of state-law immunity and qualified immunity as to Officer Bowers in his individual capacity, allowing the Heeters’ constitutional and state-law claims against him to proceed to trial. However, the court held that the City was entitled to summary judgment on the state-law claims because of an Ohio municipal immunity statute. The court reversed solely on the issue of municipal immunity for the City, and otherwise affirmed the district court's decision. View "Heeter v. Bowers" on Justia Law

The case involves Hattie Tanner, who was convicted of murder and served seventeen years in prison before her conviction was set aside due to insufficient evidentiary support. After her release, Tanner filed a lawsuit against David Walters, a retired police detective, alleging that he violated her constitutional rights by falsifying investigation reports and providing false testimony, leading to her wrongful conviction. Walters sought summary judgment based on qualified immunity, which the district court partially granted and partially denied. The court allowed Tanner's claims for fabrication of evidence and malicious prosecution to proceed to trial. Walters appealed this decision.Previously, the district court found that Tanner's claims for fabrication of evidence and malicious prosecution should proceed to trial. Walters appealed this decision, arguing that he was entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that a reasonable jury could conclude that Walters knowingly fabricated evidence against Tanner, and thus he was not entitled to qualified immunity on Tanner's fabrication-of-evidence claim. The court also found that a reasonable jury could find that Walters's false statements influenced the decision to charge Tanner, and that without these false statements, there would not have been probable cause to prosecute Tanner. Therefore, Walters was not entitled to qualified immunity on Tanner's malicious prosecution claim. View "Tanner v. Walters" on Justia Law

The case involves Kamel Chaney-Snell, who was arrested by Deputy Andrew Young and Officer Andrew Teichow during a search of his girlfriend's house. Chaney-Snell claimed that after he peacefully surrendered, Young punched him in the face, and one of the officers kneed him in the back and dragged him across the floor. He sued Young and Teichow under 42 U.S.C. § 1983, alleging excessive force and failure to intervene. The district court denied qualified immunity to both officers.The officers' appeals raised three questions. First, whether the court must accept Chaney-Snell’s claim that Young gratuitously punched him despite Chaney-Snell’s guilty plea for attempting to resist arrest. The Sixth Circuit found that it lacked jurisdiction over Young’s Heck claim, and his judicial-estoppel claim failed on the merits.Second, whether the Fourth Amendment allows officers to use unnecessary force on arrestees if the force qualifies as “de minimis”. The court held that gratuitous force violates the Fourth Amendment even if the force is minor and causes no serious injury.Finally, whether Chaney-Snell established a “failure to intervene” theory of liability. The court found that qualified immunity protects the officers from Chaney-Snell’s failure-to-intervene claims.The Sixth Circuit affirmed in part, reversed in part, and dismissed in part for lack of jurisdiction. View "Chaney-Snell v. Young" on Justia Law

The case revolves around the death of Darius Caraway, who overdosed while serving a murder sentence at Whiteville Correctional Facility in Tennessee, operated by CoreCivic, Inc. Caraway's estate, represented by his mother, sued CoreCivic and three of its officials, alleging that they violated Caraway's Eighth Amendment rights by failing to protect him from overdosing. The estate argued that CoreCivic deliberately understaffed the facility, leading to inadequate screening of prison guard applicants, smuggling of illegal drugs, and lack of supervision, which allowed fentanyl to proliferate at Whiteville. The estate claimed that the defendants knew about this proliferation but did nothing about it, leading to Caraway's death by overdose.The United States District Court for the Western District of Tennessee dismissed the estate’s complaint, stating that the claims were conclusory allegations of unconstitutional conduct devoid of well-pled factual support. The estate appealed this dismissal to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit affirmed the district court's decision. The court found that the estate failed to adequately allege that Caraway faced an objectively excessive risk of harm from unfettered access to drugs inside Whiteville. The court also found that the estate failed to sufficiently allege that the defendants knew of a drug problem at Whiteville or that they didn't reasonably respond to the alleged risk. The court concluded that the estate failed to meet the requirements of a failure-to-protect claim under the Eighth Amendment. The court also dismissed the estate's procedural claims, stating that the district court properly treated the motion as one to dismiss and that the estate had forfeited its argument about the district court's failure to issue a scheduling order. View "Caraway v. CoreCivic of Tennessee, LLC" on Justia Law

In this case, a taxi driver, Lufti Said Saalim, sued Walmart and several individuals, including deputy sheriffs, alleging violations of his Fourth and Fourteenth Amendment rights and state law claims following an incident at a Walmart in Toledo, Ohio. Saalim claimed that while waiting for his passengers at a loading zone, he was approached by a Walmart employee and subsequently by Deputy Sheriff Jeffrey Bretzloff, who was working as a private security guard for Walmart. Saalim alleged that Bretzloff used excessive force during the encounter, including pulling him out of his cab and using a taser on him.The United States Court of Appeals for the Sixth Circuit reversed the district court's decision that granted Bretzloff qualified immunity on Saalim's Fourth Amendment claim. The court held that Saalim plausibly alleged that Bretzloff's use of force was unreasonable and violated the Fourth Amendment. The court also found that this right was clearly established at the time of the incident.However, the court affirmed the district court's dismissal of Saalim's Fourteenth Amendment claim, agreeing that it was identical to his Fourth Amendment claim. The court also affirmed the dismissal of Saalim's state law claims of assault, battery, intentional infliction of emotional distress, false arrest, and false imprisonment, as they were barred by the statute of limitations.The court remanded the case for further proceedings on Saalim's Fourth Amendment claim against Bretzloff; his § 1983 municipal liability claim against Sheriff Navarre; and his state law claims of negligent hiring, supervision, training, and retention and vicarious liability against the Walmart Defendants and McNett. View "Saalim v. Walmart, Inc." on Justia Law

In the case under review, the appellant, Lafayette Deshawn Upshaw, was convicted of crimes associated with two separate incidents occurring on the same day: a gas station robbery and a home invasion. Following exhaustion of state court remedies, Upshaw sought habeas relief in federal court, upon which the district court granted relief on claims of ineffective assistance of counsel and violation of the Batson rule.The ineffective assistance of counsel claim was based on trial counsel's failure to investigate potential alibi witnesses. The Batson rule violation claim was derived from the State’s use of peremptory challenges to strike six Black jurors. The Warden appealed the district court's decision, but the United States Court of Appeals for the Sixth Circuit affirmed the lower court's ruling.The court found that the trial counsel's failure to investigate potential alibi witnesses and to request an adjournment to rectify the situation was unreasonable and prejudicial to Upshaw, constituting ineffective assistance of counsel. The court also found that the State's failure to provide race-neutral reasons for striking certain jurors, coupled with the trial court's failure to properly evaluate the State's justifications, constituted a violation of the Batson rule. The court held that even a single racially motivated peremptory strike requires relief. The court concluded that both of these errors entitled Upshaw to habeas relief. View "Upshaw v. Stephenson" on Justia Law