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

In a case before the United States Court of Appeals for the Sixth Circuit, Thurman King sued Officers Zachary Abbate and Jason Bradley, the City of Rockford, the Rockford Public Safety Department, and other municipal officers under 42 U.S.C. § 1983 and state law for incidents stemming from a 2019 traffic stop. The district court granted partial summary judgment in favor of the defendants but denied their motion for summary judgment on qualified and governmental immunity grounds for King’s federal and state tort claims against Abbate and Bradley. The court also denied their motion on King’s Monell claim against the City and Department. The defendants appealed this denial.The Sixth Circuit affirmed in part, and reversed in part, the district court’s denial of qualified and governmental immunity to Abbate and Bradley. The court found that Abbate was entitled to qualified and governmental immunity for his takedown maneuver against King but not for the subsequent conduct on the ground. The court also dismissed the City and Department’s appeal for lack of appellate jurisdiction.The court found a genuine dispute of material fact as to whether Abbate and Bradley had probable cause to believe that King committed any underlying crimes, which defeated the officers' claims for summary judgment on King’s false arrest claim. The court affirmed the district court's denial of governmental immunity to Abbate and Bradley for their conduct on the ground but reversed the denial of governmental immunity to Abbate for his takedown maneuver. The court also affirmed the district court’s denial of governmental immunity to Abbate and Bradley for King’s false arrest claim. View "King v. City of Rockford, MI" on Justia Law

In this case, the plaintiff, Jason Schwebke, brought a lawsuit against his employer, United Wholesale Mortgage (UWM), alleging disability discrimination under state and federal law. Schwebke, who is deaf, claimed that UWM failed to provide him with necessary accommodations and retaliated against him. In response, UWM participated in extensive discovery procedures for several months without invoking its right to arbitration as per the parties' employment agreement.Seven months into the case, UWM moved to compel arbitration. The district court denied this motion, reasoning that UWM had implicitly waived its right to compel arbitration through its conduct. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision.The appellate court applied the principle from the Supreme Court's decision in Morgan v. Sundance, Inc., which held that a party may waive its contractual right to arbitrate by participating in litigation. In applying this rule, the court found that UWM's actions—participating in extensive discovery, failing to raise arbitration in its defense, and not moving to compel arbitration until seven months into the case—were completely inconsistent with reliance on the arbitration agreement. The court therefore concluded that UWM had implicitly waived its right to arbitration. View "Schwebke v. United Wholesale Mortgage LLC" on Justia Law

In this case, the plaintiff, Kellie Farris, called 911 alleging that another woman had damaged her car. However, responding sheriff's deputies ended up arresting Farris instead. Farris alleged that during her arrest and subsequent transportation to jail, the deputies used excessive force. She also claimed that she was suicidal and that the deputies' actions were unreasonable given her state of mind.In response, the deputies argued that they had probable cause for Farris's arrest based on corroborated eyewitness testimony and physical evidence in Farris's car. They further contended that Farris's suicidal behavior justified the level of force used to restrain and control her.On reviewing the case, the United States Court of Appeals for the Sixth Circuit agreed with the lower court's decision to grant summary judgment in favor of the defendants. The court found that the deputies had probable cause for Farris's arrest and that the force used was minimal and reasonably necessary given Farris's behavior. The court also rejected Farris's claim that the county had an unconstitutional policy of inadequately training its deputies, finding no evidence of deliberate indifference or a pattern of excessive force.The court noted that states may pass laws or prison policies that protect detainees' privacy or liberty more than the Constitution demands, but Farris failed to show how this was relevant to her Fourth Amendment claim.In conclusion, the Sixth Circuit affirmed the district court's decision, ruling in favor of the deputies and the county on all counts. View "Farris v. Oakland County" on Justia Law

A medical resident, Dr. Jacquelyn Mares, was dismissed from Wright State University’s (WSU) obstetrics and gynecology residency program due to ongoing complaints and escalating disciplinary actions related to her unprofessional behavior. Following her dismissal, Mares was also terminated from her position at Miami Valley Hospital, where she was employed during her residency. As a result, Mares sued WSU, the hospital, its owner-operator Premier Health Partners, and several WSU employees, alleging violations of her procedural and substantive due process rights, as well as various contract-based state law claims. The district court granted summary judgment to the defendants.In its ruling, the United States Court of Appeals for the Sixth Circuit held that WSU did not violate Mares' procedural due process rights when it dismissed her from the residency program. The court found that WSU had followed its internal procedures closely and that Mares was afforded more than enough process. Also, the court held that WSU did not violate Mares' substantive due process rights. It determined that WSU's decision to dismiss her was not arbitrary or capricious, nor was it conscience-shocking. Finally, the court held that Miami Valley Hospital did not breach its contractual duties when it terminated Mares after her dismissal from WSU’s residency program. The court concluded that the hospital acted within the scope of the employment contract. Therefore, the court affirmed the district court’s decision to grant the defendants' summary judgment. View "Mares v. Miami Valley Hospital" on Justia Law

In this case, the United States Court of Appeals for the Sixth Circuit was presented with an appeal involving an Ohio hospital's mandate for its employees to get COVID-19 vaccines. The plaintiffs, a group of current and former employees who had requested religious exemptions from the mandate, sued the hospital for religious discrimination under Title VII and Ohio Revised Code § 4112 after the hospital initially rejected all religious exemptions. The district court dismissed the case for lack of subject matter jurisdiction and failure to state a claim, leading to this appeal.The appellate court affirmed the dismissal for the majority of plaintiffs, ruling they lacked standing to sue because they could not demonstrate sufficient injury. However, the court reversed the dismissal for two of the plaintiffs who had resigned after their religious exemption requests were denied but before the hospital changed its policy and granted all religious exemptions. The court held that these two plaintiffs had plausibly alleged that they were forced to resign, or "constructively discharged", and thus had standing to sue.Furthermore, the court found that these two plaintiffs had sufficiently alleged that the hospital failed to provide reasonable accommodations for their religious practices and treated them differently from other employees. Consequently, they had stated plausible claims for relief under Title VII and Ohio Revised Code § 4112. The case was remanded for further proceedings concerning these two plaintiffs. View "Savel v. MetroHealth System" on Justia Law

In this case, a prisoner, Kyle Brandon Richards, appealed a district court's decision to dismiss his civil rights suit under 42 U.S.C. § 1983. The lawsuit was dismissed because Richards reportedly failed to exhaust his administrative remedies. The plaintiff alleged sexual harassment, retaliation, and destruction of property by Resident Unit Manager Thomas Perttu. Specifically, Richards claimed that Perttu prevented him from filing grievances related to the alleged abuse by destroying or ripping them up.The defendant, Perttu, moved for summary judgment, arguing that Richards had failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(a). The district court denied the motion due to questions of fact. After an evidentiary hearing, a magistrate judge recommended that the district court find that Richards had failed to exhaust his administrative remedies. Richards appealed, alleging errors by the district court, bias by the magistrate judge, and the need for a free transcript of the evidentiary hearing.The United States Court of Appeals for the Sixth Circuit addressed whether the district court should have ordered an evidentiary hearing to decide the disputed questions of fact intertwined with the exhaustion issue. The Court of Appeals found that the Seventh Amendment required a jury trial when the resolution of the exhaustion issue under the PLRA would also resolve a genuine dispute of material fact regarding the merits of the plaintiff’s substantive case. Therefore, the Court of Appeals reversed the judgment of the district court and remanded the case for further proceedings. View "Richards v. Perttu" on Justia Law

The plaintiff, Ilya Kovalchuk, was driving his vehicle when off-duty police officer Matthew Ward began driving erratically behind him, ordered him to pull over, and held Kovalchuk at gunpoint without any justification. Kovalchuk filed a lawsuit against Ward and the City of Decherd, Tennessee, alleging that Ward violated his Fourth Amendment rights and that the City’s failure to investigate Ward’s background before hiring him led to Kovalchuk’s injuries. The district court dismissed the claims against the City, finding that Kovalchuk failed to adequately plead allegations supporting municipal liability.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court determined that in order to survive a motion to dismiss, a plaintiff must allege facts that, if accepted as true, are sufficient to state a claim to relief that is plausible on its face. The court found that Kovalchuk did not plausibly allege that the City of Decherd was deliberately indifferent to a known or obvious consequence of its decision to hire Ward. According to the court, Kovalchuk's allegations of "issues," "concerns about [Ward’s] demeanor and professionalism," and his "fail[ure] to complete [a] training program" were insufficient to establish a causal link between Ward's hiring and Kovalchuk's injury. The court further stated that a plaintiff cannot use discovery to bridge the gap between a deficient pleading and the possibility that a claim might survive upon further investigation. Therefore, the court affirmed the district court's dismissal of Kovalchuk's claims against the City of Decherd. View "Kovalchuk v. City of Decherd" on Justia Law

The case revolves around a plaintiff, Jorden Brown, who was tasered by Officer Samuel Giles while fleeing from police, resulting in injuries to Brown. Brown sued Officer Giles, the police chief, and the municipality he was arrested in under 42 U.S.C. § 1983, alleging excessive use of force and violation of his Fourth Amendment rights. He also claimed that department policies or customs enabled these violations. The defendants moved to dismiss the case, and the district court granted the dismissal on the grounds that Brown failed to allege a violation of clearly established law. Brown appealed this decision.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court ruled that Brown failed to show that it was clearly established that tasing him in this particular context was excessive. They referred to previous cases where it was deemed reasonable for officers to tase fleeing suspects. The court further dismissed Brown's claim that the taser hit his head, arguing that during a chase, it is unrealistic to expect an officer to aim precisely to avoid the head.The court also rejected Brown's claim that Officer Giles continued to tase him after he was incapacitated. Brown had provided video footage of the incident which, according to the court, showed that Officer Giles tased Brown only once. The court therefore ruled that Officer Giles was entitled to qualified immunity. As Brown's claims against Officer Giles failed, his claims against the police chief and the municipality were also dismissed. View "Brown v. Giles" on Justia Law

In this case, DeShawn Anderson-Santos, a juvenile detainee at the Kent County Juvenile Detention Center, claimed he suffered a head injury after being pushed by corrections officer Derek Leshan. Anderson-Santos filed a lawsuit against Leshan under 42 U.S.C. § 1983, the Fourteenth Amendment, and the Eighth Amendment, alleging the use of excessive force. Leshan sought summary judgment arguing qualified immunity. The district court denied Leshan’s motion, finding that there was a genuine dispute of material fact as to whether Leshan had used excessive force, thus violating the Eighth Amendment. The court also found that Leshan was not entitled to qualified immunity at the summary judgment stage. Leshan appealed this decision to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit dismissed the appeal for lack of jurisdiction. The court noted that while denials of summary judgment are not typically appealable on an interlocutory basis, an exception exists for denials of claims of qualified immunity if the appeal turns on a legal issue. However, the court found that Leshan's appeal ultimately turned on questions of fact rather than an issue of law, divesting the court of jurisdiction. The court explained that a defendant seeking to challenge a denial of qualified immunity based on a genuine dispute of material fact may invoke the court's jurisdiction by conceding the plaintiff's version of the facts. However, the court determined that Leshan did not truly concede Anderson-Santos' version of the facts, thus the court lacked jurisdiction to hear the appeal. View "Anderson-Santos v. Kent County" on Justia Law

In this case before the United States Court of Appeals for the Sixth Circuit, the defendant, Charles O’Neill, appealed the judgment of the district court. O’Neill was charged with sexually exploiting a minor and receiving or distributing child pornography. He pleaded guilty to both charges but reserved the right to appeal the district court’s denial of his motion to suppress evidence obtained from his home and a barn he owned. The evidence included large numbers of photographs of nude and partially nude minor boys on O’Neill’s phone and iPad, and a computer, camcorder, camera, digital storage devices, miscellaneous clothing, and a vibrator found in the barn.The district court found that although the affidavits from the police officers used to obtain search warrants contained false statements and lacked probable cause, the officers had not knowingly or recklessly misled the issuing magistrate, and their reliance on the warrants was objectively reasonable under the good-faith exception in United States v. Leon.On appeal, the Sixth Circuit affirmed the district court's decision, agreeing that none of the exceptions to the good-faith exception applied. The court found that the officers' errors in the affidavits were negligent rather than reckless, the affidavits weren't "bare bones" as they contained more than conclusory claims and were far from devoid of factual support, and the warrants weren't facially deficient. The court noted that the officers' reliance on the search warrants was objectively reasonable, and therefore the fruits of their searches shouldn't be suppressed. The court also noted that even if it shared the dissenting judge's view on the officers' state of mind, it would likely conclude that the district court's denial of the suppression motion was proper because the remaining content of the affidavit would likely establish probable cause. View "United States v. O'Neill" on Justia Law