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

A trade association representing internet companies challenged the enforcement of a new Tennessee statute designed to protect minors from social media risks. The law requires social media companies to verify the ages of all prospective account holders and secure parental consent before allowing minors to create accounts. It also mandates that parents be given tools to supervise their children’s accounts. The association argued that its members would suffer unrecoverable compliance costs and that the law would restrict their and their users’ First Amendment rights.The United States District Court for the Middle District of Tennessee denied the association’s motion for a preliminary injunction. The district court concluded that the association had not established irreparable harm, finding that the alleged loss of First Amendment freedoms was not sufficiently certain or imminent, and that unrecoverable compliance costs did not qualify as irreparable harm. Because the court found no irreparable harm, it did not consider the other preliminary injunction factors.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial. The appellate court disagreed with the lower court’s analysis of irreparable harm, holding that both unrecoverable compliance costs and the loss of First Amendment freedoms can satisfy the threshold requirement for irreparable harm. The court explained that compliance costs need not be extraordinary to be considered irreparable and that the chilling effect on speech, even before enforcement, can constitute irreparable harm if enforcement is likely and imminent. The Sixth Circuit vacated the district court’s order and remanded the case for further consideration of all preliminary injunction factors, directing the lower court to weigh the harm asserted and address the remaining legal standards as appropriate. View "NetChoice, LLC v. Skrmetti" on Justia Law

The case concerns Michael C. Hoffpowier, who was investigated after his estranged wife, B.H., reported to law enforcement that he had scheduled an appointment at her workplace under a false name and had a history of harassing her across multiple states. Officers responding to the scene located Hoffpowier’s vehicle in a nearby parking lot. Upon approaching, they observed behavior they interpreted as a potential flight risk, including the vehicle being put in reverse. Hoffpowier was handcuffed after failing to comply with commands to approach an officer. While detained, officers reviewed text messages between Hoffpowier and B.H. and, with his consent, observed binoculars and a gun magazine in his vehicle. A search of the vehicle revealed firearms and a silencer.The United States District Court for the Eastern District of Tennessee denied Hoffpowier’s motion to suppress the evidence obtained from the search, concluding that the handcuffing did not constitute an arrest and that there was a reasonable basis to believe the vehicle contained evidence related to stalking. The magistrate judge’s report and recommendation to deny suppression was adopted after Hoffpowier’s objections were overruled, in part because he did not update his arguments in light of the report’s analysis. Hoffpowier subsequently pleaded guilty to possession of an unregistered silencer.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court held that the officers’ use of handcuffs during the investigatory stop was reasonable given the circumstances and did not convert the stop into an arrest. It further held that the presence of binoculars visible in the vehicle provided a reasonable basis to believe that the vehicle contained evidence pertinent to the stalking offense, justifying the warrantless search under the search-incident-to-arrest exception. View "United States v. Hoffpowier" on Justia Law

A group of Guatemalan nationals were recruited under the H-2A visa program by a Michigan agricultural company and its owners to work seasonal jobs between 2017 and 2019. The plaintiffs alleged that the defendants illegally charged recruitment fees, underpaid wages, forced them to live in poor conditions, confiscated personal documents, limited their freedom, and threatened them with deportation if they complained. The plaintiffs claimed these actions violated federal anti-trafficking laws, the Fair Labor Standards Act, Michigan labor and trafficking statutes, and state contract law.In the United States District Court for the Western District of Michigan, the case proceeded to a jury trial. The jury found in favor of the plaintiffs on most claims, awarding both compensatory and punitive damages, while denying certain claims against one defendant and rejecting the defendants’ counterclaims. The district court denied the defendants’ motions for mistrial, to dismiss for forum non conveniens, for a new trial, and for remittitur of punitive damages. The court entered judgment for the plaintiffs, including damages, attorney fees, and costs.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the punitive damages awarded were not grossly excessive or arbitrary and thus did not violate due process, applying the guideposts from BMW of North America, Inc. v. Gore and State Farm Mutual Automobile Insurance Co. v. Campbell. The court also found no abuse of discretion in the district court’s evidentiary rulings, denial of a mistrial, or in allowing the case to proceed in Michigan rather than Guatemala. The court further concluded that alleged statute of limitations defenses were either inapplicable or waived. The Sixth Circuit affirmed the district court’s judgment in all respects. View "Gomez-Echeverria v. Purpose Point Harvesting, LLC" on Justia Law

A fourteen-year-old student, JPZ, was suspended from school following an altercation. The school principal, Melissa Arendts, notified JPZ's mother and requested JPZ be picked up. Upon arrival, JPZ's grandmother found him isolated and awaiting questioning by Scott Labish, a sheriff’s deputy serving as a school resource officer. Labish, in uniform, questioned JPZ, allegedly in a threatening manner, and told him about a “Three Strike” policy that would result in criminal prosecution and expulsion after another infraction. JPZ became distressed, left school, and subsequently died by suicide at home several hours later. JPZ's father, Brian Zimmermann, as administrator of JPZ’s estate, sued Arendts, Labish, the school district, and Macomb County, alleging federal due process violations and state law claims.The United States District Court for the Eastern District of Michigan dismissed the wrongful death claim but allowed four other claims to proceed: deprivation of substantive due process, conspiracy, intentional infliction of emotional distress, and Monell liability. Defendants moved to dismiss the remaining claims based on qualified and state governmental immunity and deficiencies in the Monell claim. The district court denied these motions in part, leading to an interlocutory appeal by the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial de novo. The Sixth Circuit held that the facts did not support a substantive due process claim under the state-created danger doctrine, as the defendants neither increased JPZ’s risk of harm from a third party nor acted with deliberate indifference. The conspiracy and Monell claims failed because no underlying constitutional violation was adequately alleged. The court also found the defendants entitled to state governmental immunity for the intentional infliction of emotional distress claim, as the conduct alleged did not indicate malice. The Sixth Circuit reversed the district court’s denial of the motions to dismiss and remanded the case. View "Zimmermann v. Labish" on Justia Law

Dennis O’Connor had two non-interest-bearing financial accounts with private companies. After O’Connor lost contact with these companies, they transferred his accounts to the State of Michigan under the state’s Uniform Unclaimed Property Act, which governs the handling of unclaimed property. Michigan took custody of O’Connor’s accounts and deposited the funds into its general fund, where the money could generate interest for the state. When O’Connor learned of this, he contended that the state’s failure to pay him the interest earned while holding his money violated his constitutional rights.Previously, the United States District Court for the Eastern District of Michigan dismissed all of O’Connor’s claims, finding that the state took ownership of his accounts and thus owed him no interest. On an earlier appeal, the United States Court of Appeals for the Sixth Circuit affirmed the dismissal of his takings claims but vacated the dismissal of his due process claims and remanded for further proceedings. On remand, the district court again dismissed O’Connor’s due process claims, reasoning that Michigan’s ownership of the accounts meant O’Connor had no right to the interest and that the procedures provided were constitutionally sufficient.The United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that under Michigan law, the state only assumes custody—not ownership—of unclaimed property, and the original owner retains title to both the principal and any interest generated. The court found that the district court erred by following contrary state appellate precedent and by concluding that O’Connor had no property interest in the funds or the interest. The court vacated the district court’s judgment dismissing the due process claims and remanded for further proceedings, directing the lower court to analyze the due process claim based on the correct understanding that O’Connor retained ownership rights. View "O'Connor v. Eubanks" on Justia Law

A tenured law professor at a state university posted an online petition calling for military action against Israel. The university responded by placing the professor on administrative leave and restricting his campus access while it investigated whether his actions violated university policy or law. The investigation included notices to the professor, requests for evidence, and allegations from students, but had not progressed beyond the preliminary fact-finding stage. No formal hearing or charges had been initiated by the university at the time of the lawsuit.The professor filed suit in the United States District Court for the Eastern District of Kentucky, seeking a preliminary injunction to stop the university’s actions. The university moved for abstention under the doctrine established in *Younger v. Harris*, arguing that the ongoing university investigation constituted a state proceeding warranting federal court abstention. The district court agreed with the university and abstained from hearing the case, prompting the professor to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s abstention decision de novo. The Sixth Circuit held that the university’s investigation was still in a preliminary, investigatory stage and did not constitute an ongoing formal proceeding as required under the *Younger* abstention framework. The court distinguished the circumstances from prior cases involving formal disciplinary hearings, noting that no formal charges or hearings had yet been initiated. As a result, the Sixth Circuit reversed the district court’s decision to abstain and remanded the case for consideration of the professor’s motion for a preliminary injunction. View "Woodcock v. Univ. of Kentucky" on Justia Law

In this case, two individuals served as members of the Human Relations Commission (HRC) in Hamtramck, Michigan, which oversaw city-owned flagpoles along a main avenue. For a decade, the HRC operated under an unwritten policy that allowed residents to request flags to be flown, including flags of different nations and various groups, such as the Pride flag. After a change in city administration in 2021, tension arose when the HRC flew the Pride flag in 2022. Responding to controversy, the newly elected City Council enacted a resolution in 2023 restricting the flagpoles to only certain flags—specifically, the American, Michigan, Hamtramck, and Prisoner of War flags, as well as those of nations representing the city’s international character. When the plaintiffs raised the Pride flag in defiance, the City Council removed them from the HRC and stripped the HRC’s authority over the flagpoles.The plaintiffs then brought suit in the United States District Court for the Eastern District of Michigan, alleging violations of the Free Speech, Establishment, and Equal Protection Clauses. The district court granted summary judgment in favor of the City and its officials, finding that after the 2023 resolution, the flagpoles served as a forum for government speech, not private speech, and that the resolution was facially neutral regarding religion and not motivated by religious purpose. The court also determined that the plaintiffs had not adequately developed an equal protection claim.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the City permissibly closed the flagpoles to private speech, making them a vehicle solely for government speech, and thus the plaintiffs’ Free Speech Clause claim failed. The court also held that the plaintiffs’ Establishment Clause claim was unavailing, as there was no evidence the resolution’s primary purpose was to advance religion. Finally, the court concluded the plaintiffs had forfeited their equal protection claim by not developing it. View "Gordon v. City of Hamtramck, Mich." on Justia Law

A 15-year-old, ELG, participated in a vocational program for teenagers that included a visit to a Michigan district court. During a lecture given by Judge Kenneth J. King about his career, ELG fell asleep, which offended Judge King. In response, Judge King orchestrated a plan to “scare her straight” by having ELG handcuffed, placed in a detention cell, required to wear a prison jumpsuit, and later subjected her to a mock trial in front of her peers, which was streamed online. There was no official court proceeding, case number, or record associated with these actions, and Judge King later admitted his actions were intended to teach ELG a lesson for perceived disrespect.Following these events, Latoreya Till, ELG’s mother, filed a lawsuit in the United States District Court for the Eastern District of Michigan. The complaint alleged violations of ELG’s Fourth Amendment rights and state law torts. Judge King moved to dismiss the case, arguing judicial immunity protected him from suit. The district court denied his motion, finding that the conduct alleged was not within the scope of judicial functions. Judge King appealed, and Till cross-appealed on an alternative theory.The United States Court of Appeals for the Sixth Circuit reviewed the lower court’s denial of the motion to dismiss de novo. It held that Judge King’s alleged actions were not judicial acts because they did not constitute functions normally performed by a judge nor did they occur in his judicial capacity. The court further found that Till’s alternative argument, based on a “complete absence of all jurisdiction,” was inapplicable. The Sixth Circuit affirmed the district court’s decision, holding that Judge King was not entitled to judicial immunity at this stage of the proceedings. View "Till v. King" on Justia Law

A public interest law firm known for its advocacy on religious liberty and free speech was included on a list of "hate groups" published by the Southern Poverty Law Center (SPLC) in 2015, and has remained on the list since. In February 2019, Michigan’s Attorney General and the then-Director of the Michigan Department of Civil Rights issued a press release responding to the SPLC’s latest "Hate Map," noting an increase in such groups and announcing new state initiatives. Although the press release did not name the law firm, it linked to the SPLC report. The law firm alleged that it suffered reputational, economic, and organizational harm as a result, claiming a chilling effect on its First Amendment rights and seeking declaratory and injunctive relief against the officials.The United States District Court for the Western District of Michigan initially found that the law firm had adequately pleaded standing, as the press release arguably conferred the state’s “imprimatur” on the SPLC’s list, potentially harming the law firm’s reputation. The court denied the officials’ motion to dismiss at the pleading stage. However, following discovery and summary judgment motions, the district court concluded that the law firm failed to present sufficient evidence of a cognizable injury in fact traceable to the defendants’ actions or likely to be redressed by the requested relief, and granted summary judgment for the officials on standing grounds.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s summary judgment ruling de novo. The Sixth Circuit held that the law firm had not demonstrated that the officials’ press release caused it any incremental reputational or economic injury beyond that resulting from the SPLC’s designation, nor that any such injury was ongoing or likely to recur. The court further found the law firm’s diversion-of-resources theory forfeited and unsupported. The judgment for the defendants was affirmed. View "Am. Freedom Law Center v. Nessel" on Justia Law

The dispute centers on a property owner that purchased a vacant and dilapidated parcel in Nashville’s East Bank district, intending to redevelop it into a multi-family residential project in accordance with local zoning rules. The owner submitted a building permit application that, according to its allegations, fully complied with all applicable zoning requirements. However, in mid-2022, the local government placed an indefinite “development hold” on the property, effectively barring any consideration or approval of the permit. The stated reason was that authorities were assessing possible routes for a planned major roadway that might require acquisition of part of the property. As a result, the owner claims the property has become undevelopable and unsellable, resulting in millions of dollars in carrying costs.After unsuccessful efforts to have the hold lifted, the owner filed suit in state court, alleging violations of the Takings and Due Process Clauses of the U.S. Constitution and the Tennessee Constitution. The case was removed to the United States District Court for the Middle District of Tennessee, where the defendants moved to dismiss on several grounds, including untimeliness and qualified immunity. The district court, on its own initiative, dismissed the complaint for lack of “jurisdictional” ripeness, reasoning that there had been no final decision on the permit application.On appeal, the United States Court of Appeals for the Sixth Circuit considered only the ripeness issue. The court held that the owner’s claims were both constitutionally and prudentially ripe because the local government’s development hold constituted a definitive, final decision barring any development of the property. The appellate court reversed the district court’s dismissal and remanded the case for further proceedings on the remaining issues. View "SW Nashville EB Owner, LLC v. Metro. Gov't of Nashville & Davidson Cnty." on Justia Law