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

HRT Enterprises owned an 11.8-acre parcel adjacent to Detroit’s Coleman A. Young International Airport, with about 20 percent of the property falling within a regulated runway “visibility zone” that restricted development. Over time, the City of Detroit acquired other properties in a nearby area for airport compliance but did not purchase HRT’s. By late 2008, HRT’s property had become vacant and vandalized, and HRT alleged it could no longer use, lease, or sell the property due to City actions and regulatory restrictions.HRT first sued the City in Michigan state court in 2002, alleging inverse condemnation, but the jury found for the City; the Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied leave to appeal. In 2008, HRT sued in federal court, but the United States District Court for the Eastern District of Michigan dismissed the action without prejudice because HRT had not exhausted state remedies. HRT then filed a second state suit in 2009, which was dismissed on res judicata grounds; the Michigan Court of Appeals affirmed. HRT did not seek further review.In 2012, HRT filed the present action in federal court, alleging a de facto taking under 42 U.S.C. § 1983. The district court denied the City’s preclusion arguments, granted summary judgment to HRT on liability, and held that a taking had occurred, leaving the date for the jury. A first jury found the taking occurred in 2009 and awarded $4.25 million; the court ordered remittitur to $2 million, then a second jury, after a new trial, awarded $1.97 million.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings, holding that HRT’s claim was ripe, not barred by claim or issue preclusion, that the district court properly granted summary judgment on liability, and that its remittitur decision was not an abuse of discretion. View "HRT Enterprises v. City of Detroit" on Justia Law

HRT Enterprises pursued a takings claim against the City of Detroit after losing a jury verdict in state court in 2005. Subsequently, HRT filed suit in federal court in 2008, alleging a post-2005 violation under 42 U.S.C. § 1983. The United States District Court for the Eastern District of Michigan dismissed the federal action, citing the requirement from Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985), to exhaust state remedies first. HRT then returned to state court, where its claim was dismissed on claim preclusion grounds, a decision affirmed by the Michigan Court of Appeals. After the state court denied compensation, HRT initiated a federal § 1983 action in 2012. The case was stayed when the City filed for bankruptcy, prompting HRT to participate in bankruptcy proceedings to protect its compensation rights. Ultimately, the bankruptcy court excepted HRT’s takings claim from discharge, allowing the federal case to proceed. After two jury trials, the district court entered judgment for HRT in September 2023.Following its success, HRT moved for attorney fees under 42 U.S.C. § 1988, presenting billing records that included work from related state and bankruptcy proceedings. The district court applied a 33% discount to the claimed hours due to commingled and poorly described entries, set an average hourly rate, and awarded $720,486.25, which included expert witness fees. Both parties appealed aspects of the fee award to the United States Court of Appeals for the Sixth Circuit.The Sixth Circuit held that the district court erred by concluding it had no discretion to award fees for work performed in the related state-court and bankruptcy proceedings, as such fees are recoverable when the work is necessary to advance the federal litigation. The court also found the district court erred in awarding expert witness fees under § 1988(c) in a § 1983 action, as the statute does not authorize such fees for § 1983 claims. The appellate court vacated the fee award and remanded for recalculation consistent with its opinion. View "HRT Enterprises v. City of Detroit" on Justia Law

A research scientist who had worked for over a decade at a public university in Ohio coauthored several well-regarded articles during her tenure. After she left the university for a new position, allegations of research misconduct surfaced regarding some of her publications. The university convened an investigative committee, as required by federal regulations due to its receipt of federal funding. The committee found that she had committed research misconduct and recommended barring her from future university employment, retracting or correcting certain articles, and reported its findings to relevant journals and her current employer. The scientist alleged that the committee deviated from standard investigatory procedures, failed to provide exculpatory evidence, and did not require proof of intent or recklessness.The United States District Court for the Southern District of Ohio dismissed her complaint, which had sought equitable relief under federal and state law. The court held that sovereign immunity shielded the university’s Board of Trustees and the officials sued in their official capacities from most claims. It found several claims time-barred and determined that the remaining constitutional claims, including due process and equal protection, failed on the merits. The court declined to exercise supplemental jurisdiction over the state-law claims against individuals in their personal capacities.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The court held that sovereign immunity barred all claims against the Board of Trustees and all state-law claims against the officials in their official capacities. As to the remaining federal due process claims, the court determined that the plaintiff failed to identify a constitutionally protected liberty interest under the stigma-plus doctrine and that the alleged conduct—even if malicious or in violation of confidentiality regulations—did not amount to conscience-shocking behavior under substantive due process standards. View "Pichiorri v. Burghes" on Justia Law

Luther Poynter was incarcerated at the Barren County Detention Center in Kentucky for contempt of court related to unpaid child support. After a brief period in COVID-19 observation, he was moved to a general-population cell with two other detainees, Scotty Wix and Timothy Guess. Both Wix and Guess had extensive histories of violent behavior and multiple documented assaults against other detainees while in the facility. Shortly after Poynter entered the cell, Guess and Wix attacked him without apparent provocation, causing a traumatic brain injury and lasting physical impairment.The United States District Court for the Western District of Kentucky reviewed the case after Poynter, through his guardian, sued the jailer and Barren County under 42 U.S.C. § 1983, alleging deliberate indifference to his safety in violation of the Due Process Clause of the Fourteenth Amendment. The district court granted summary judgment to the county, concluding there was insufficient evidence of a constitutional violation or municipal liability, and held that Poynter had not shown he was placed at a substantial risk of harm or that reasonable steps were not taken to abate that risk.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. The appellate court held that Poynter had presented sufficient evidence for a reasonable jury to find that Barren County had a custom of failing to properly classify detainees with violent histories, recklessly disregarded a known risk, and that this failure caused Poynter’s injuries. The Sixth Circuit clarified that municipal liability can attach even without identifying a specific individual as the violator, so long as the unconstitutional harm resulted from a municipal policy or custom. The Court of Appeals reversed the district court’s summary judgment and remanded the case for further proceedings. View "Poynter v. Bennett" on Justia Law

The plaintiffs in this case are mental health counselors who provide “talk therapy” services, including counseling to minors, guided by their Catholic faith. Their services consist exclusively of spoken words, and they do not use physical or aversive techniques. Some of their clients, including minors with parental consent, seek counseling to address issues related to gender identity or sexual orientation, such as wanting to align their gender identity with their biological sex or to reduce same-sex attraction in accordance with their religious beliefs. The plaintiffs assert an ethical and religious duty to help clients pursue such goals if requested.In 2023, Michigan enacted laws forbidding licensed therapists from engaging in “conversion therapy” with minors, defined as efforts to change an individual’s sexual orientation or gender identity, but specifically permitting counseling that assists with gender transition. The plaintiffs filed suit in the United States District Court for the Western District of Michigan, seeking a preliminary injunction to block enforcement of these laws, arguing that the prohibition restricts their speech based on its content and viewpoint in violation of the First Amendment. The district court denied the motion, reasoning that the counseling in question was conduct, not speech, for constitutional purposes.On appeal, the United States Court of Appeals for the Sixth Circuit found that the plaintiffs had standing and disagreed with the district court’s characterization of the therapy as conduct rather than speech. The court held that the Michigan law is a content- and viewpoint-based restriction on speech and is therefore subject to strict scrutiny under the First Amendment. The court determined that the State did not demonstrate a sufficient justification for the restriction, and that the plaintiffs are likely to succeed on the merits of their claim. The Sixth Circuit reversed the district court’s denial of the preliminary injunction and remanded for prompt entry of an injunction preventing enforcement of the law during the case. View "Catholic Charities of Jackson v. Whitmer" on Justia Law

In this case, an individual attended the 2022 Kentucky Derby in Louisville, Kentucky, with a group to engage in expressive activities such as preaching, distributing literature, and displaying signs near the event. The area surrounding Churchill Downs was subject to a special event permit issued by the city government, which allowed Churchill Downs to restrict access to certain public streets and sidewalks to ticket holders and credentialed individuals. The plaintiff and his group entered a fenced-off, restricted area beyond posted “No Trespassing” signs, despite lacking event tickets or credentials. After repeated warnings from private security and law enforcement, the plaintiff was arrested by a Kentucky State Police trooper for criminal trespass.The plaintiff filed suit in the United States District Court for the Western District of Kentucky, asserting claims under 42 U.S.C. § 1983 for violations of his free speech, free exercise, and due process rights, as well as a Monell municipal liability claim against the city government and claims against the arresting officer. The district court granted summary judgment in favor of the defendants on all claims. It found the free speech restriction content-neutral and justified under intermediate scrutiny, concluded the free exercise claim was not properly developed, determined the permitting scheme was not unconstitutionally vague, dismissed the Monell claim for lack of an underlying constitutional violation, and granted qualified immunity to the arresting officer.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court held that the restricted area was a limited public forum and the ticketing and access restrictions were content-neutral and survived intermediate scrutiny. The court found no evidence of viewpoint discrimination, held that ample alternative channels for communication existed, and determined that the plaintiff failed to preserve his free exercise claim and did not establish a due process violation. The Monell claim failed for lack of a constitutional violation, and qualified immunity was properly granted to the officer. View "Blankenship v. Louisville-Jefferson Cnty. Metro Gov't" on Justia Law

TwinSpires, an Oregon-based electronic wagering platform, facilitates interstate betting on horseraces. Under the federal Interstate Horseracing Act (IHA), such betting is lawful if the operator obtains consent from both the state where the bet is accepted and the state where the race occurs, as well as the relevant racetrack. Michigan, however, enacted a law requiring additional state-specific licensing for platforms like TwinSpires to accept bets from Michigan residents. After TwinSpires partnered with Michigan’s only racetrack and obtained the requisite license, its license was suspended when the racetrack temporarily lost its own license. Even after the racetrack’s license was restored, Michigan maintained the suspension of TwinSpires’ license, prompting the company to sue, arguing that Michigan’s requirements conflicted with the IHA.The United States District Court for the Western District of Michigan granted a preliminary injunction, preventing Michigan from enforcing its licensing requirements against TwinSpires. The district court found that the IHA preempted Michigan’s additional licensing regime, concluding that TwinSpires was likely to succeed on the merits of its preemption claim and that other injunction factors favored TwinSpires.The United States Court of Appeals for the Sixth Circuit reviewed the preliminary injunction for abuse of discretion, applying de novo review to legal conclusions and clear error review to factual findings. The Sixth Circuit affirmed the district court’s order, holding that the IHA conflict-preempts Michigan’s licensing requirement for interstate wagering platforms. The court concluded that Michigan’s law imposed an additional regulatory hurdle beyond what the IHA requires, interfering with the federal scheme and frustrating Congress’s intended objectives. The court also found that the remaining factors for a preliminary injunction—irreparable harm, balance of equities, and public interest—favored TwinSpires. View "Churchill Downs Tech. Initiatives Co. v. Mich. Gaming Control Bd." on Justia Law

The plaintiff claimed that Michigan had taken custody of between $200 and $600 in unclaimed property belonging to her. She alleged that, under Michigan’s Uniform Unclaimed Property Act, the state would return her property if she requested it but would not pay her any interest earned while the property was in the state’s custody, unless the property was originally interest bearing. Without first submitting a claim to reclaim her property, she brought a suit under 42 U.S.C. § 1983 against officials responsible for Michigan’s unclaimed property program, arguing that the state’s failure to pay interest amounted to an unconstitutional taking in violation of the Fifth Amendment. She sought declaratory and injunctive relief on behalf of herself and a putative class.The United States District Court for the Eastern District of Michigan dismissed her case, concluding that she lacked Article III standing because Michigan law did not grant her a property right to interest earned on her unclaimed property. The district court reasoned that, without such a property right, she could not demonstrate an injury from the state’s retention of interest.On appeal, the United States Court of Appeals for the Sixth Circuit found that the plaintiff had standing, as her complaint alleged a concrete financial injury: the state’s withholding of interest that she claimed was rightfully hers. The court held that the district court improperly conflated the merits of whether she was entitled to interest with the standing inquiry. The Sixth Circuit reversed the district court’s dismissal for lack of standing and remanded for further proceedings, emphasizing that the record was insufficient to resolve the merits of the takings claim at this stage. View "Hendershot v. Stanton" on Justia Law

A Michigan State Trooper conducted a traffic stop after observing a vehicle with expired registration. The passenger, Adam Santos, was identified as a convicted felon, currently on probation, and flagged in police databases as possibly armed and dangerous. During the stop, the trooper noticed Santos acting nervously and avoiding searching a cross-body bag when asked for identification. After obtaining the driver’s consent to search the vehicle, the trooper removed both occupants from the car for safety. While frisking Santos, the trooper felt a weight in the bag consistent with a firearm. A struggle ensued when the trooper attempted to open the bag, and a gun was recovered. Santos was indicted for unlawful possession of a firearm by a felon.The United States District Court for the Western District of Michigan denied Santos’s motion to suppress the gun, finding that the officer’s actions were justified by concerns for safety and that the driver voluntarily consented to the vehicle search. The court also found the frisk of Santos and the subsequent search of the bag permissible, given the reasonable suspicion and probable cause developed during the stop.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s legal conclusions de novo and its factual findings for clear error. The appellate court held that the trooper did not violate Santos’s Fourth Amendment rights. The stop was lawfully initiated, and the questions and actions taken by the officer, including the removal of both occupants and the frisk of Santos, were justified by safety concerns based on specific, articulable facts. The court affirmed the district court’s denial of the suppression motion, holding that neither the duration nor the scope of the stop nor the search of Santos’s bag was unconstitutional. View "United States v. Santos" on Justia Law

Milder Escobar-Temal, a Guatemalan national, unlawfully entered the United States in 2012, living and working in Nashville, Tennessee. In October 2022, Nashville police responding to a domestic incident found three firearms at his residence. He was charged with unlawful possession of a firearm under 18 U.S.C. § 922(g)(5)(A), which prohibits possession of firearms by individuals unlawfully present in the United States. Escobar-Temal had no prior criminal convictions except a dismissed charge for driving without a license.The United States District Court for the Middle District of Tennessee denied Escobar-Temal’s motion to dismiss the indictment, in which he argued that § 922(g)(5)(A) violated the Second Amendment both facially and as applied. The district court reasoned that, while the Second Amendment’s protections may extend to unlawfully present persons, historical tradition supported disarming those who had not sworn allegiance to the state. After denying the motion, Escobar-Temal pleaded guilty but reserved the right to appeal the constitutional issue.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The Sixth Circuit held that the Second Amendment does protect individuals unlawfully present in the United States if they have developed sufficient connections to the national community. However, it further held that there is a longstanding historical tradition of disarming groups lacking a formal relationship with the government, such as unlawfully present noncitizens, due to regulatory difficulties rather than inherent dangerousness. Therefore, the court concluded that § 922(g)(5)(A) does not violate the Second Amendment, either on its face or as applied to Escobar-Temal, and affirmed his conviction and sentence. View "United States v. Escobar-Temal" on Justia Law