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

James Williams, at midnight on New Year’s Day in Canton, Ohio, fired numerous shots into the air from a patio enclosed by a wooden privacy fence as part of a celebratory tradition. Officer Robert Huber, responding to the gunfire, arrived at the scene and witnessed Williams begin a second round of shooting. Without announcing his presence or issuing a warning, Huber shot Williams through the fence, resulting in Williams’s death. Williams’s wife sued Huber and the City of Canton, alleging excessive force under the Fourth Amendment and municipal liability.The United States District Court for the Northern District of Ohio reviewed Huber’s motion for summary judgment based on qualified immunity. The court determined that there was a genuine dispute of material fact regarding whether Williams had turned his rifle toward Huber or continued firing into the air, and whether celebratory gunfire was common in Canton at that time. Based on these unresolved factual questions, the district court denied Huber’s motion for summary judgment, finding that a reasonable jury could conclude Huber lacked probable cause to believe Williams posed a threat sufficient to justify deadly force.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of summary judgment. The Sixth Circuit held that, construing the facts in the light most favorable to Williams’s wife, Huber violated the Fourth Amendment by using deadly force without probable cause to believe Williams posed a threat of serious physical harm. The court further concluded that this violation was clearly established law in an “obvious” case, as no reasonable officer would have believed it permissible to shoot a person committing a misdemeanor—discharging a gun into the air in celebration—without warning or evidence of a threat. View "Williams v. City of Canton" on Justia Law

A company sought to erect a digital billboard in a small Ohio municipality but was prevented from doing so by the local billboard ordinance, which included restrictions on size, location, and type of billboards permitted. The ordinance specifically banned “variable message” (digital) signs and implemented a “cap and replace” rule, allowing new billboards only if older ones were removed. The ordinance also contained several exemptions, including one for “public service” signs, which were allowed to display information like time or weather if not used for advertising.Previously, the United States District Court for the Southern District of Ohio granted summary judgment to the municipality, upholding the ordinance against the company’s First Amendment challenges. On appeal, the United States Court of Appeals for the Sixth Circuit determined that the exemption for public service signs was an unconstitutional, content-based restriction under the First Amendment, but remanded the case for the district court to determine whether the invalid exemption was severable from the rest of the ordinance.On remand, the district court found that the unconstitutional provision could be severed and that the remainder of the ordinance survived intermediate scrutiny, granting judgment again in favor of the municipality. The company appealed.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the public-service exemption was severable under Ohio law, applying the three-part test from Geiger v. Geiger. The court further held that the remaining provisions of the ordinance were content-neutral and survived intermediate scrutiny because they were narrowly tailored to significant governmental interests such as traffic safety and aesthetics. The court also held that the company was not entitled to damages or attorney fees, as it was not a prevailing party under 42 U.S.C. § 1988(b). View "Norton Outdoor Advertising, Inc. v. Village of St. Bernard" on Justia Law

In this case, the petitioner was convicted and sentenced to death for the murder and robbery of two men in a Kentucky convenience store in 1987. After being identified as a suspect, he confessed to the crimes but later asserted an insanity defense at trial. His mental health was evaluated by state experts, who found him competent and not suffering from a mental illness that would have excused his conduct. At trial, the defense presented testimony from the petitioner and a psychologist, but the jury found him guilty on all counts and recommended the death penalty. The penalty phase included limited mitigation evidence and testimony.Following his conviction and sentencing, the petitioner pursued direct appeals and post-conviction relief in Kentucky state courts, including before the Kentucky Supreme Court, and sought certiorari from the United States Supreme Court, which was denied multiple times. He then filed a federal habeas corpus petition in the United States District Court for the Eastern District of Kentucky, asserting several constitutional claims, including ineffective assistance of counsel, improper jury instructions on the insanity defense, and cumulative error. The district court denied relief, but granted certificates of appealability on several issues.On appeal, the United States Court of Appeals for the Sixth Circuit first held that the Antiterrorism and Effective Death Penalty Act (AEDPA) is constitutional, rejecting the argument that it unconstitutionally restricts federal habeas review. Applying AEDPA deference, the court found that the Kentucky Supreme Court’s decisions regarding the jury instructions and most of the ineffective assistance of counsel claims were neither contrary to nor unreasonable applications of clearly established federal law. Claims not subject to AEDPA deference failed under de novo review because the petitioner could not show prejudice. The cumulative error claim was found to be procedurally defaulted. Accordingly, the Sixth Circuit affirmed the denial of the habeas petition in full. View "Sanders v. Plappert" on Justia Law

Scott Williams was elected to serve on the Addison Community School Board for a six-year term and was chosen by his fellow board members to act as president for one year. During his presidency, Williams had a dispute with a staff member, leading to allegations that he harassed staff and improperly requested confidential information. Following an investigation and resolution drafted by board members, the Board voted to censure Williams and remove him from the presidency. Williams was not informed of the allegations against him before the meeting where his removal was voted upon.Williams filed suit in the United States District Court for the Eastern District of Michigan, alleging, among other claims, a violation of the Fair and Just Treatment clause of the Michigan Constitution and asserting that the school district was liable under respondeat superior. The district court granted summary judgment to the defendants on all claims, including the federal constitutional claims, and denied Williams’s motion for partial summary judgment on his Fair and Just Treatment claim. The district court chose to exercise supplemental jurisdiction over the state law claims after dismissing the federal claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the district court abused its discretion by retaining supplemental jurisdiction over Williams’s Fair and Just Treatment claim. The appellate court found that the state law claim presented a novel and complex issue under Michigan law, particularly because Michigan courts have not yet determined whether a private right of action exists under the Fair and Just Treatment clause. The court held that, given the dismissal of all federal claims and the complexity of the remaining state constitutional issue, the district court should have declined to exercise supplemental jurisdiction. As a result, the Sixth Circuit vacated the district court’s judgment on the Fair and Just Treatment claim and remanded with instructions to dismiss this claim without prejudice. View "Williams v. Addison Community Schools" on Justia Law

The plaintiff, a magistrate in the domestic-relations division of a county court, declared her candidacy for a judicial seat alongside a fellow magistrate, who was also a court administrator. During her campaign, the plaintiff distributed literature that criticized her opponent’s work schedule and duties, suggesting that the opponent performed trivial administrative tasks and questioning her competence based on personal circumstances. These campaign materials were perceived by the administrative judge as undermining the integrity of the court and casting both the court and its staff in an unfavorable light. After the plaintiff lost the primary election, the administrative judge terminated her employment as a magistrate.Prior to this appeal, the United States District Court for the Southern District of Ohio dismissed the plaintiff’s suit brought under 42 U.S.C. § 1983, which alleged a violation of her First Amendment free-speech rights. The district court ruled that the court itself was not a legally cognizable entity subject to suit, that sovereign immunity barred claims for money damages against the administrative judge in her official capacity, and that the plaintiff failed to state a plausible free-speech claim against the administrative judge. The plaintiff appealed only the dismissal of her free-speech claim.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. It held that, because the plaintiff occupied a confidential or policymaking position and her campaign speech addressed matters related to court policy and politics in a manner that undermined the loyalty and efficient functioning required by her employer, her termination did not violate the First Amendment. The court affirmed the district court’s judgment, finding that the balancing test usually applied to public employee speech was unnecessary under these circumstances. The court also rejected the plaintiff’s arguments regarding insubordination, the scope of judicial candidate speech protections, and the applicability of strict scrutiny. View "Gaines v. Cross" on Justia Law

The defendant, a native and citizen of Jamaica, repeatedly entered the United States unlawfully after being removed several times due to criminal convictions, including firearms and drug offenses. In May 2023, he was apprehended at the Ambassador Bridge in Detroit and charged with unauthorized reentry following his removal subsequent to conviction for an aggravated felony, violating 8 U.S.C. § 1326. This constituted his eleventh felony conviction and fifth felony immigration conviction under § 1326.After being indicted in the United States District Court for the Eastern District of Michigan, the defendant moved to dismiss the charge, arguing that § 1326 violates the Fifth Amendment’s equal protection guarantee by discriminating against Mexican and other Latino immigrants. The district court rejected his motion, finding that he failed to link the legislative history and intent of the 1929 Act and its predecessors to the 1952 Immigration and Nationality Act, which codified § 1326. The court also determined that he did not provide evidence of disparate impact or invidious discriminatory purpose regarding § 1326’s enforcement, and adopted the analysis from United States v. Carrillo-Lopez, 68 F.4th 1133 (9th Cir. 2023). The district court sentenced him to 51 months’ imprisonment and he timely appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s refusal to dismiss the indictment de novo and its factual findings for clear error. The appellate court held that the defendant failed to establish discriminatory intent or disparate impact under the Arlington Heights framework. The court emphasized that the legislative history of the 1929 Act is not controlling for § 1326, and Congress is not required to purge previous discriminatory intent when enacting new legislation. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Myrie" on Justia Law

The case involves a defendant who was convicted by a jury of aiding and abetting kidnapping after an incident in Detroit. The events began when the defendant was shot during a confrontation involving rival gang members, after which the victim was taken by the defendant’s associates for interrogation. The victim was confined, threatened, and beaten at the defendant’s home, with parts of the incident recorded and later shared in an Instagram group chat. After these events, the victim was driven around, further assaulted, and eventually released.Prior to this appeal, the United States District Court for the Eastern District of Michigan oversaw the trial. The court denied the defendant’s motions to suppress evidence obtained from social media accounts, motions to exclude alleged co-conspirator statements, and ruled partially in favor of the government’s effort to limit cross-examination of the victim. After a weeklong trial, the jury acquitted the defendant of conspiracy but found him guilty of aiding and abetting kidnapping. The district court sentenced him to 198 months in prison and imposed several special conditions of supervised release, some of which were only included in the written judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. It affirmed the district court on four grounds: the denial of suppression motions, the admission of co-conspirator statements, the limitation on cross-examination, and the sufficiency of the evidence for conviction. The appellate court held that the defendant’s constitutional and evidentiary challenges failed. However, it found a discrepancy between the oral pronouncement of sentence and the written judgment regarding two special conditions of supervised release. The court remanded the case to the district court to resolve this discrepancy and, if needed, to consider the constitutional challenges to those conditions. View "United States v. Blake" on Justia Law

Law enforcement officers responded to a report of an open door at Chad Taylor’s townhouse in Boone County, Kentucky. Inside, they found signs of recently fired gunshots, including bullet holes and spent shell casings. After obtaining search warrants, officers found ammunition and methamphetamine in Taylor’s possession. Taylor admitted to using methamphetamine and exhibited paranoid, erratic behavior, claiming people were watching him. The following day, Taylor was found at his home with a loaded Glock 19, and ballistics matched it to the earlier gunfire. Taylor had prior felony convictions for drug trafficking, intimidation, and misdemeanor domestic battery.A grand jury indicted Taylor for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). The United States District Court for the Eastern District of Kentucky initially detained Taylor but later released him on conditions due to his history of substance abuse and the risk he posed. Taylor moved to dismiss the indictment, arguing that the statute was unconstitutional both facially and as applied. The district court denied the motion, finding Taylor dangerous based on his prior convictions, and subsequently sentenced him to 30 months’ imprisonment after he pled guilty but reserved his right to appeal the constitutional issue.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the constitutionality of § 922(g)(1) as applied to Taylor in light of recent circuit precedent. The appellate court held that the dangerousness assessment required for firearm disqualification is distinct from the assessment for pretrial detention. Applying the standard set forth in United States v. Williams, the court found that Taylor’s offense conduct and criminal history—including felony drug trafficking, intimidation, and domestic battery—demonstrated that he was dangerous. The court affirmed the district court’s judgment, holding that § 922(g)(1) is constitutional as applied to Taylor. View "United States v. Taylor" on Justia Law

A real estate developer purchased a vacant parcel of land in Worthington, Ohio, previously owned by a youth home. The property was primarily zoned for public or institutional uses such as parks, hospitals, and churches. The developer sought to build a mixed-use project and applied for rezoning and development plan approval. After public meetings where concerns about greenspace, traffic, and density were raised, the municipal planning commission tabled the initial application. The developer later reduced the number of proposed residential units, but the commission still declined to recommend approval, and the city council denied the rezoning application. Subsequently, the city amended its comprehensive plan to emphasize greenspace. The developer, having purchased the property after waiving a rezoning contingency, filed suit, alleging constitutional violations due to the city’s refusal to rezone and amend the comprehensive plan.The United States District Court for the Southern District of Ohio dismissed most of the developer’s claims at the motion-to-dismiss stage, including due process counts, and granted summary judgment to the city on the remaining regulatory takings and declaratory judgment claims. The developer appealed, challenging the dismissal and grant of summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the grant of summary judgment and dismissal de novo. The court held that the city’s actions did not constitute a regulatory taking under the Penn Central factors, as the developer lacked a reasonable investment-backed expectation of rezoning approval and the city’s actions had legitimate public purposes. The court also found that the zoning ordinance was not unconstitutional beyond fair debate and that the developer failed to allege a cognizable property interest or arbitrary government action for its due process claims. The Sixth Circuit affirmed the district court’s judgment in all respects. View "Lifestyle Communities, Ltd. v. City of Worthington" on Justia Law

A Kentucky citizen who is subject to lifetime sex offender registration due to prior convictions challenged a new state law requiring certain sex offenders to display their full legal names on social media accounts they create or control. The law defines covered offenses as those committed against minors and applies to a wide range of social media platforms, with exceptions for services such as email and search engines. The plaintiff, who uses social media anonymously for personal and political expression, alleged that the law’s disclosure requirement would subject him and his family to harassment and would force him to stop using social media.The United States District Court for the Western District of Kentucky reviewed the case. Initially, it found the plaintiff was likely to succeed on his claim that the law infringed his First Amendment right to post anonymously and was overbroad, granting a preliminary injunction that barred all Kentucky County Attorneys from enforcing the law. The court later denied class certification, concluding the plaintiff lacked standing to represent absent class members against other County Attorneys and failed to meet requirements for class actions. Consequently, the injunction was narrowed to apply only to the named defendant and protect only the plaintiff.On appeal, the United States Court of Appeals for the Sixth Circuit found the district court erred in its facial overbreadth analysis. The Sixth Circuit held that a proper facial challenge under the First Amendment requires a comprehensive review of the law’s scope and its constitutional and unconstitutional applications, as described in Moody v. NetChoice, LLC. The district court had failed to conduct this thorough analysis and focused too narrowly on the plaintiff’s own circumstances. The Sixth Circuit vacated the preliminary injunction and remanded the case for further proceedings consistent with the proper two-step facial overbreadth approach. View "Doe v. Burlew" on Justia Law