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

Aaron Pulsifer was terminated from his position as Dean of Students and Assistant Principal at Westshore Christian Academy. He subsequently filed a lawsuit against the Academy, alleging various state and federal employment discrimination claims based on race and sex. Pulsifer claimed that his termination was retaliatory, following his complaints about unequal treatment and concerns regarding the school's main funder. The Academy argued that Pulsifer's role involved significant religious functions, invoking the ministerial exception to preclude judicial review of his claims.The United States District Court for the Western District of Michigan granted summary judgment in favor of the Academy. The court held that Pulsifer's position involved important religious duties, thus falling under the ministerial exception, which prevents courts from intervening in employment disputes involving key religious employees. Pulsifer appealed the decision, arguing both procedural and substantive errors.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court found that the district court had properly converted the Academy's motion to dismiss into a motion for summary judgment and provided Pulsifer with a reasonable opportunity to respond. On the substantive issue, the Sixth Circuit agreed with the lower court, holding that Pulsifer's role at the Academy included vital religious duties such as leading devotions, conducting prayers, and guiding students' spiritual development. These responsibilities placed him within the ministerial exception, precluding judicial review of his employment discrimination claims.The Sixth Circuit affirmed the district court's judgment, emphasizing that the ministerial exception applies to employees who perform essential religious functions, regardless of their involvement in secular administrative tasks. View "Pulsifer v. Westshore Christian Academy" on Justia Law

The defendant was found guilty of felony possession of a firearm after a bench trial, having waived his right to a jury trial. The case arose from a traffic stop on December 5, 2020, where the defendant was stopped for driving past a stop bar at a traffic light. During the stop, the defendant refused to provide identification and was subsequently arrested. A search of his vehicle revealed marijuana and a loaded firearm. The defendant challenged the traffic stop, his arrest, and the vehicle search as violations of his Fourth Amendment rights and argued that his conviction was not supported by sufficient evidence.The United States District Court for the Southern District of Ohio denied the defendant's motion to suppress the evidence. The court found that the initial traffic stop was supported by probable cause, the arrest was justified by probable cause, and the vehicle search was permissible under the automobile exception. The court also found sufficient evidence to support the conviction based on the stipulated facts presented during the bench trial.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decisions. The appellate court agreed that the traffic stop was justified by probable cause due to the observed traffic violation. The arrest was deemed lawful based on probable cause for multiple offenses, including driving with a suspended license and refusing to provide identification. The search of the vehicle was upheld under the automobile exception, as the officers had probable cause to believe it contained illegal contraband. The court also found that the defendant's stipulation to all elements of the offense constituted a waiver of his right to challenge the sufficiency of the evidence. The conviction was affirmed. View "United States v. Watson" on Justia Law

Deangelus Thomas was indicted on two counts of being a felon in possession under 18 U.S.C. § 922(g)(1) for his involvement in a shooting. Although his indictment indicated potential enhanced penalties due to his criminal history, he was not formally indicted as an armed career criminal. A jury found him guilty of both counts. During sentencing, Thomas argued that he could not be sentenced under the Armed Career Criminal Act (ACCA) because he had not been indicted for it, and the jury had not found that he had three prior violent-felony convictions committed on different occasions. The district judge disagreed and imposed an enhanced 432-month sentence based on Thomas's criminal history.The United States District Court for the Western District of Tennessee at Memphis followed then-binding Sixth Circuit precedent, which allowed the judge to find the necessary facts for the ACCA enhancement by a preponderance of the evidence. Thomas appealed, and the Sixth Circuit affirmed the sentence. However, the Supreme Court later decided Erlinger v. United States, which required a jury to find the three-occasions element of an ACCA conviction. The Supreme Court remanded Thomas's case for further consideration in light of Erlinger.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that Erlinger errors are subject to harmless-error review. The court found that the error in Thomas's case was harmless beyond a reasonable doubt because the Shepard documents and the Presentence Report provided clear evidence that Thomas's three prior violent felonies occurred on different occasions. The court also rejected Thomas's double jeopardy argument, concluding that the enhanced sentence did not violate his Fifth and Sixth Amendment rights. Consequently, the Sixth Circuit affirmed Thomas's enhanced sentence. View "United States v. Thomas" on Justia Law

The case involves a challenge to Michigan's newborn screening program, which collects blood samples from newborns to test for diseases. The plaintiffs, consisting of parents and their children, argue that the program's retention and use of these blood samples without consent violate their Fourth and Fourteenth Amendment rights. The plaintiffs claim that the state's actions constitute a coercive, non-consensual taking and keeping of baby blood for the state's profit.Initially, the United States District Court for the Eastern District of Michigan dismissed the plaintiffs' complaint. However, a prior panel of the United States Court of Appeals for the Sixth Circuit reversed and remanded several claims, allowing the plaintiffs to pursue their Fourth and Fourteenth Amendment claims for injunctive and declaratory relief. On remand, the district court granted judgment in favor of the plaintiffs on nearly all their remaining claims and ordered the defendants to return or destroy the stored blood spots and data.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's judgment. The appellate court held that the defendants' actions of storing and using the blood spots and data did not violate the plaintiffs' Fourteenth Amendment substantive-due-process rights, as these actions did not constitute medical care or intrude on the parents' right to direct their children's medical care. Additionally, the court found that the plaintiffs failed to prove a possessory interest in the blood spots and data, which is necessary to establish a Fourth Amendment seizure claim. Consequently, the appellate court vacated the injunction requiring the defendants to destroy the stored data. View "Kanuszewski v. Michigan Dep't of Health & Human Services" on Justia Law

Luis Martinez Jr. died in February 2021, and his body was taken by the Wayne County Medical Examiner’s Office (WCMEO). Despite identifying his next of kin, the WCMEO did not contact them. The family hired a social worker who located Luis Jr.'s body in April 2021, by which time it was severely decomposed and had to be cremated. The family sued Wayne County and various officials under § 1983 for a Fourteenth Amendment procedural due process violation, a Monell liability claim, and state-law claims.The United States District Court for the Eastern District of Michigan granted the defendants' motion to dismiss. The court found that the alleged conduct did not constitute a clearly established constitutional violation and that the Monell claim failed due to a lack of supporting facts. The court declined to exercise supplemental jurisdiction over the state-law claims, dismissing them without prejudice.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 defendants' conduct did not violate a clearly established constitutional right, as existing precedent did not address delayed notification leading to natural decomposition. The court also found that the Monell claim failed because the complaint did not allege sufficient facts to show a policy or custom of unconstitutional conduct or a failure to train. The court concluded that without a clearly established constitutional violation, the Monell claim could not succeed. View "Martinez v. Wayne Cnty., Mich." on Justia Law

In 2017, the Saginaw County Sheriff’s Office seized fourteen firearms during a domestic-violence investigation involving Benjamin Heinrich. Heinrich's uncle, Gerald Novak, and distant cousin, Adam Wenzel, claimed ownership of the firearms and sought their return. Sheriff William Federspiel refused to return the firearms, arguing that Novak and Wenzel had not proven ownership. Novak and Wenzel then sued Federspiel under 42 U.S.C. § 1983 and Michigan law, asserting various federal constitutional and state claims.The United States District Court for the Eastern District of Michigan granted summary judgment to Federspiel on all claims and denied Novak and Wenzel’s motion for partial summary judgment. The court found that qualified immunity protected Federspiel in his personal capacity and that Novak and Wenzel had not established constitutional violations. It also held that Michigan law does not recognize a cause of action to sue municipal officials for constitutional torts and that Novak and Wenzel could not establish the elements of claim and delivery.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s grant of summary judgment to Federspiel on the individual-capacity takings claims, procedural-due-process claims, substantive-due-process claims, Fourth Amendment claims, and inverse-condemnation claims. However, it vacated the grant of summary judgment on the official-capacity and injunctive-relief takings claims, official-capacity Second Amendment claims, and the claim-and-delivery action. The court remanded these claims for further proceedings, noting that Novak and Wenzel’s affidavits created a genuine issue of material fact regarding ownership of the firearms, and that the district court should address whether Federspiel’s actions were consistent with historical firearm regulation. View "Novak v. Federspiel" on Justia Law

Elfido Gonzalez Castillo, a native and citizen of Mexico, illegally entered the United States in 1981 and became a lawful permanent resident in 1989. In 2009, he applied for naturalization but failed to disclose a recent indictment for sexually abusing his niece. He became a naturalized citizen in October 2009 and pleaded guilty to the offense two months later. In 2019, the government sought to revoke his citizenship, and in 2022, a court ordered its cancellation due to his fraudulent procurement. Subsequently, the Department of Homeland Security initiated removal proceedings against him under 8 U.S.C. § 1227(a)(2)(E)(i) for a crime of child abuse.An immigration judge ordered Gonzalez's removal, and the Board of Immigration Appeals upheld this decision. Gonzalez sought review in the Third Circuit, which transferred the case to the Sixth Circuit, determining that venue lay elsewhere.The United States Court of Appeals for the Sixth Circuit reviewed the case and concluded that Gonzalez was not deportable under the child-abuse provision because he was a naturalized citizen at the time of his conviction. The court relied on the precedent set by the Supreme Court in Costello v. INS, which held that deportation provisions do not apply to individuals who were citizens at the time of their conviction. The court noted that the statutory language and the rule of lenity supported this interpretation. Consequently, the Sixth Circuit granted Gonzalez's petition for review, vacated the order of removal, and remanded the case for further proceedings consistent with its opinion. View "Gonzalez Castillo v. Bondi" on Justia Law

Daniel Lockridge, a decorated combat Marine, was involved in methamphetamine trafficking after returning to the U.S. in 2009. He initially used methamphetamine to manage his PTSD and later began selling it, eventually becoming a significant supplier in Chattanooga, Tennessee. Lockridge pleaded guilty to aiding and abetting possession with intent to distribute methamphetamine and was sentenced to 210 months in prison followed by three years of supervised release. His supervised release conditions included mandatory mental-health and substance-abuse treatment, as directed by a probation officer.The United States District Court for the Eastern District of Tennessee imposed these conditions, and Lockridge objected, arguing that the court must preauthorize any inpatient treatment and set a frequency for drug testing, rather than delegating these decisions to a probation officer. The district court overruled his objections, leading to Lockridge's appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court did not relinquish its authority by not specifying the details of the treatment programs at sentencing. Instead, it retained the discretion to make these decisions closer to the time of Lockridge's supervised release, allowing the probation officer to assess his needs and recommend appropriate treatment. The court emphasized that the ultimate authority to modify or enforce the conditions of supervised release remains with the district court, ensuring compliance with Article III of the U.S. Constitution.The Sixth Circuit affirmed the district court's decision, concluding that the delegation of certain responsibilities to the probation officer did not violate constitutional principles, as the district court retained the final decision-making authority. View "United States v. Lockridge" on Justia Law

Plaintiffs, Carvin Thomas and Terrell Lawrence, filed a class-action lawsuit against members of the Tennessee Board of Parole, alleging that the use of a computer test, STRONG-R, to determine parole eligibility violated their constitutional right to due process. They claimed that the test produced inaccurate results due to inadequate training of correctional employees and that the results were kept secret, preventing inmates from challenging them effectively. Both plaintiffs experienced changes in their STRONG-R scores without any new negative behavior, leading to parole denials based on these scores.The United States District Court for the Middle District of Tennessee dismissed the complaint, concluding that the plaintiffs failed to state a plausible claim for relief. The court found that Tennessee’s parole statutes do not confer a protected liberty interest in parole, as they do not create a legitimate expectation of parole.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that Tennessee’s parole statutes do not sufficiently constrain the Board’s discretion to deny parole, thus not creating a constitutionally recognized entitlement to parole. The court noted that while the plaintiffs identified serious issues with the STRONG-R test, the lack of a protected liberty interest in parole precluded their due process claims. Consequently, the court affirmed the dismissal of the plaintiffs' complaint. View "Thomas v. Montgomery" on Justia Law

Lavonce Makiri Smith was stopped by police in Grand Rapids, Michigan, and a gun was found in his pocket. Smith moved to suppress the evidence, arguing that the police lacked reasonable suspicion to stop and frisk him. The incident began when Detective Garza was involved in a car accident, and Lt. Jonathan Wu, who was also at the scene, noticed a silver Chrysler that matched a stolen vehicle report. The Chrysler circled the area multiple times, and Wu observed three young Black men, including Smith, walking towards his car from the direction of the Chrysler. Wu suspected they were associated with the stolen car and might be planning a carjacking or robbery.The United States District Court for the Western District of Michigan held an evidentiary hearing where Wu testified. The court found Wu's testimony credible and concluded that the officers had reasonable suspicion to stop and frisk Smith. The court ruled that the stop was lawful due to the reasonable suspicion of criminal activity, and the frisk was justified based on the totality of the circumstances suggesting Smith was armed and dangerous. Smith entered a conditional guilty plea, preserving his right to appeal the suppression decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that the stop was supported by reasonable suspicion. The court found that Wu's observations and the behavior of Smith and his companions, combined with the context of the stolen vehicle and the high-crime area, provided a particularized and objective basis for suspecting criminal activity. The court also rejected Smith's arguments challenging the district court's factual findings and application of the law, concluding that the totality of the circumstances justified the stop and frisk. View "United States v. Smith" on Justia Law