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

In Michigan, citizens can amend the state constitution through ballot initiatives without legislative approval. Two state senators and nine state representatives challenged the use of such initiatives to regulate federal elections, arguing it violated the U.S. Constitution's Elections Clause. They sought to prevent Michigan officials from enforcing these amendments.The United States District Court for the Western District of Michigan dismissed the case, ruling that the legislators lacked standing to sue under Civil Rule 12(b)(1). The court found that the plaintiffs did not demonstrate a concrete injury necessary for standing.The United States Court of Appeals for the Sixth Circuit affirmed the district court's dismissal. The appellate court held that the legislators did not have standing because they did not represent the entire legislature or a controlling bloc within it. The court distinguished this case from precedents where entire legislatures or controlling blocs had standing to sue. The court emphasized that individual legislators generally lack standing to assert institutional injuries of the legislature. The court also noted that the legislators had not shown that their votes were nullified by the amendments, as required for standing under relevant Supreme Court precedents.The Sixth Circuit concluded that the legislators' claims did not meet the requirements for standing under Article III of the U.S. Constitution, as they did not suffer a concrete and particularized injury. The court affirmed the district court's dismissal of the case. View "Lindsey v. Whitmer" on Justia Law

Jaylin Morton was indicted for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). Morton moved to dismiss the indictment, arguing that the prosecution violated his Second Amendment rights. The district court denied his motion, and Morton conditionally pleaded guilty, retaining the right to appeal the denial of his motion to dismiss.The United States District Court for the Eastern District of Kentucky denied Morton’s motion to dismiss, reasoning that his prior felonies demonstrated that he was a serious and direct threat to public safety. The court concluded that § 922(g)(1) constitutionally applied to him. Morton then appealed the district court’s decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Morton’s criminal history, which included multiple violent offenses such as shooting at his ex-girlfriend and her family, and assaulting his then-girlfriend, demonstrated his dangerousness. The court applied the framework established in United States v. Williams, which allows for disarming individuals who are deemed dangerous based on their criminal history. The court concluded that Morton’s conviction was consistent with the Second Amendment as interpreted in Williams and affirmed the district court’s denial of Morton’s motion to dismiss the indictment. View "United States v. Morton" on Justia Law

Randell Shepherd, a career coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA), invoking the Act’s presumption that he was entitled to benefits due to his over fifteen years of mining and total disability from chronic obstructive pulmonary disease (COPD), bronchitis, and emphysema. Incoal, Inc., Shepherd’s most recent employer, contested his entitlement, arguing that his disability was caused by smoking, not mining. An administrative law judge (ALJ) found Incoal’s expert opinions unpersuasive and inconsistent with the Act’s regulations and preamble, which recognize pneumoconiosis as a latent and progressive disease. The ALJ ruled that Incoal failed to rebut the presumption that Shepherd was entitled to benefits. The Benefits Review Board (BRB) affirmed the ALJ’s decision.Incoal petitioned the United States Court of Appeals for the Sixth Circuit for review, arguing that the ALJ improperly relied on the regulatory preamble over their evidence and that the presumption was effectively irrebuttable, violating the Constitution and the Administrative Procedure Act (APA). The court reviewed the case de novo, focusing on whether the ALJ’s decision was supported by substantial evidence and correctly applied the law.The Sixth Circuit held that the ALJ was entitled to reference the preamble to assess the credibility of expert opinions and found that the ALJ’s decision was supported by substantial evidence. The court noted that the BLBA’s rebuttable presumption is constitutional, as it is based on a rational relationship between the length of a miner’s career and the risk of pneumoconiosis. The court concluded that Incoal’s arguments were unpersuasive and that the ALJ applied the correct legal principles. Consequently, the court denied Incoal’s petition for review. View "Incoal, Inc. v. OWCP" on Justia Law

In 2005, Delano Hale was sentenced to death by an Ohio court for the murder of Douglas Green. Green was found dead in a motel room, wrapped in plastic bags, and had been shot multiple times. Hale was arrested driving Green's stolen vehicle and later admitted to the shooting, claiming it was in self-defense against Green's sexual advances. Hale was convicted of aggravated murder and other charges, and the jury recommended the death penalty.Hale's conviction and sentence were affirmed by the Ohio Supreme Court and the Ohio Court of Appeals. Hale filed for post-conviction relief, which was denied by the trial court and affirmed by the appellate court. He then sought federal habeas relief, raising multiple claims, including ineffective assistance of counsel and sentencing errors under Blakely v. Washington.The United States Court of Appeals for the Sixth Circuit reviewed Hale's habeas petition. The court denied Hale's claim of ineffective assistance of counsel, finding that his trial counsel's decision not to call a forensic expert was a reasonable strategic choice. The court noted that Hale's counsel had considered hiring an expert but ultimately chose a different strategy, which did not constitute deficient performance under Strickland v. Washington.The court also denied Hale's claim regarding his noncapital sentences, which were enhanced based on judicial factfinding in violation of Blakely. The Ohio Supreme Court had reviewed this claim for plain error and found no prejudice, concluding that a jury would have reached the same sentencing conclusions. The Sixth Circuit found this determination reasonable and upheld the Ohio Supreme Court's decision.The Sixth Circuit affirmed the district court's denial of Hale's habeas petition, concluding that Hale's claims did not warrant relief under the deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA). View "Hale v. Cool" on Justia Law

The plaintiffs, Glenn Bowles, Kenneth Franks, and Robert Gardner, challenged the constitutionality of Michigan's Court of Claims Act. Bowles and Franks, former police academy instructors, faced employment actions after allegations of misconduct, while Gardner, a former doctoral student, faced expulsion and subsequent employment issues due to his advocacy for migrant workers. They argued that the Act violated their Fourteenth Amendment rights by requiring Court of Appeals judges to serve on the Court of Claims, thus creating potential bias in appellate reviews and denying them jury trials.The United States District Court for the Eastern District of Michigan dismissed their complaint. The court found that the plaintiffs lacked standing as they did not demonstrate how the Court of Claims Act directly caused their injuries. Additionally, the court held that Bowles's claims were precluded due to a prior federal lawsuit and concluded that the plaintiffs' constitutional claims lacked merit.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit agreed that the plaintiffs lacked Article III standing. The court noted that the plaintiffs' injuries were not fairly traceable to the actions of Michigan's Governor and Attorney General, who were named as defendants. The court also found that the requested relief, an injunction against the enforcement of the Court of Claims Act, would not redress the plaintiffs' employment-related injuries. Consequently, the Sixth Circuit affirmed the district court's dismissal of the case on jurisdictional grounds, modifying the judgment to a dismissal without prejudice. View "Bowles v. Whitmer" on Justia Law

In May 2023, Martavious Kincaide pleaded guilty to three federal firearms offenses in the Western District of Kentucky. Deandre Swain, a criminal defendant in Kentucky state court, sought to intervene in Kincaide’s case to unseal a document titled “Plea Agreement Supplement.” Swain believed this document might contain a cooperation agreement that could aid his defense in his state court case. The Western District of Kentucky requires that all plea supplements, which may contain cooperation agreements, be sealed to protect cooperators from potential harm.The United States District Court for the Western District of Kentucky denied Swain’s motion to intervene. The court held that the General Order 2010-06, which mandates the sealing of plea supplements, was consistent with the First Amendment. The court reasoned that the order was the narrowest method to protect the safety of cooperators and that Swain’s specific interest did not override the need for consistency in applying the General Order.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The Sixth Circuit held that there is no qualified First Amendment right of access to cooperation agreements. The court applied the “experience and logic” test from Press-Enterprise Co. v. Superior Court, concluding that there is no historical tradition of public access to such documents and that public access would not play a significant positive role in the functioning of the judicial process. The court emphasized that public access to cooperation agreements could endanger cooperators and undermine government investigations. Thus, the denial of Swain’s motion to intervene was affirmed. View "United States v. Kincaide" on Justia Law

The defendant, Tarrence Parham, pleaded guilty to being a felon in possession of a firearm. During sentencing, the district court increased his base offense level, concluding that his prior Tennessee conviction for attempted second-degree murder constituted a crime of violence under the Sentencing Guidelines. Parham appealed this conclusion and the district court’s refusal to dismiss the indictment on Second Amendment grounds.The United States District Court for the Western District of Tennessee denied Parham’s motion to dismiss the indictment, which argued that 18 U.S.C. § 922(g)(1) was unconstitutional under New York State Rifle & Pistol Ass’n v. Bruen. Parham then pleaded guilty to the single-count indictment. The Probation Office determined his base offense level was 22, considering his prior conviction for attempted second-degree murder as a crime of violence. Parham objected, but the district court overruled his objection and sentenced him to 108 months’ imprisonment, relying on an unpublished opinion from the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that the elements of attempted second-degree murder in Tennessee categorically match the Guidelines’ definition of a crime of violence. The court also found that Parham’s Second Amendment challenge was foreclosed by binding precedent, specifically United States v. Williams, which upheld the constitutionality of § 922(g)(1) both facially and as applied to individuals with a history of dangerous behavior. Consequently, the Sixth Circuit affirmed the district court’s judgment, including the calculation of Parham’s base offense level and the denial of his motion to dismiss the indictment. View "United States v. Parham" on Justia Law

The defendant, Sylvester Gailes, has a history of domestic violence, including multiple incidents where he physically assaulted his partners. In 2012, he struck his girlfriend in the face, and in 2014, he dragged her by her hair and kicked her in the head. In 2018, he assaulted another ex-girlfriend, choking her and threatening her with a handgun. Gailes was convicted of domestic-violence misdemeanors for each of these incidents. Later, during a traffic accident investigation, police found Gailes in possession of two loaded pistols, leading to his indictment for violating 18 U.S.C. § 922(g)(9), which prohibits individuals convicted of domestic-violence misdemeanors from possessing firearms.The United States District Court for the Western District of Tennessee denied Gailes's motion to dismiss the indictment, in which he argued that 18 U.S.C. § 922(g)(9) is unconstitutional in light of the Supreme Court's decision in New York State Rifle & Pistol Ass’n v. Bruen. Gailes then pleaded guilty to the charges and was sentenced to 50 months in prison. He appealed the district court's decision, challenging the constitutionality of the statute under the Second Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court applied the two-step framework from Bruen, first determining that the Second Amendment's plain text covers Gailes's conduct. The court then examined whether the statute is consistent with the Nation's historical tradition of firearm regulation. The court found that historical analogues, such as surety laws and "going armed" laws, support the constitutionality of disarming individuals who pose a clear threat of physical violence. Consequently, the court held that 18 U.S.C. § 922(g)(9) is facially constitutional and affirmed the district court's judgment. View "United States v. Gailes" on Justia Law

Ohio enacted a law to prevent foreign nationals from influencing its elections by banning their political contributions and expenditures. The law defines "foreign nationals" to include lawful permanent residents, unlike the Federal Election Campaign Act (FECA), which exempts them. Plaintiffs, including advocacy organizations and lawful permanent residents, challenged the law on First Amendment grounds, arguing it violated their rights. The district court agreed, finding the law unconstitutional as applied to lawful permanent residents and issued a preliminary injunction preventing Ohio from enforcing the law against all foreign nationals.The United States District Court for the Southern District of Ohio granted the preliminary injunction, reasoning that the law was overbroad and violated the First Amendment rights of lawful permanent residents. The court allowed Ohio to enforce the law against foreign governments and political parties but severed the definition of "foreign national" to exclude lawful permanent residents. Ohio appealed the decision and requested an emergency stay of the injunction.The United States Court of Appeals for the Sixth Circuit reviewed the case and granted Ohio's motion for a stay. The court found that Ohio was likely to succeed on the merits, concluding that the law was not overbroad and did not violate the First Amendment rights of lawful permanent residents. The court held that Ohio has a compelling interest in preventing foreign influence in its elections, which includes lawful permanent residents. The court also determined that the law was narrowly tailored to serve this interest and was neither overinclusive nor underinclusive. The stay allows Ohio to enforce the law while the appeal is considered. View "OPAWL - Building AAPI Feminist Leadership v. Yost" on Justia Law

Christopher Goins challenged the constitutionality of 18 U.S.C. § 922(g)(1), which prohibits firearm possession by individuals convicted of crimes punishable by imprisonment for over a year. Goins, with multiple felony convictions, argued that the Supreme Court's decision in New York State Rifle and Pistol Association, Inc. v. Bruen rendered this statute unconstitutional as applied to him. In December 2021, Goins had an associate purchase a firearm for him, which he then took possession of, despite being on probation with a condition prohibiting firearm possession.The United States District Court for the Eastern District of Kentucky denied Goins's motion to dismiss the indictment, holding that § 922(g)(1) was constitutional as applied to him. Goins pled guilty but reserved the right to appeal the district court's decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and upheld the district court's decision. The court found that Goins's probation condition, his relatively short probation sentence for a dangerous crime, and his repeated dangerous conduct justified his disarmament under the Second Amendment. The court emphasized that historical traditions support the temporary disarmament of individuals who have engaged in dangerous conduct, such as Goins. Therefore, the court held that 18 U.S.C. § 922(g)(1) is constitutional as applied to Goins and affirmed the district court's judgment. View "United States v. Goins" on Justia Law