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

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objected, but the district court overruled his objection and sentenced him to 108 months’ imprisonment, relying on an unpublished opinion from the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision.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

In this case, the defendant was charged with possessing a stolen firearm and receiving a firearm while under felony indictment. Law enforcement found the stolen firearm in a vehicle owned by another individual, who later revealed that the defendant had left the gun in his car. The defendant admitted to touching the gun and knowing it was stolen. He was under felony indictment for other firearms offenses at the time.The United States District Court for the Southern District of Ohio denied the defendant's motion to dismiss the indictment, which argued that the statutes under which he was charged violated the Second Amendment. During jury selection, the defendant raised a Batson challenge against the prosecutor's peremptory strike of the last black juror on the panel. The district court found the prosecutor's reasons for the strike to be race-neutral and allowed it. The jury convicted the defendant on both counts, and he was sentenced to 18 months' imprisonment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court upheld the district court's denial of the motion to dismiss, finding that the statutes in question were consistent with historical firearm regulations and did not violate the Second Amendment. The court also affirmed the district court's rejection of the Batson challenge, concluding that the prosecutor's race-neutral explanation for the peremptory strike was credible and not pretextual. The Sixth Circuit affirmed the defendant's conviction and sentence. View "United States v. Gore" on Justia Law

Timothy Hall participated in a protest in Detroit, where he was tackled and injured by a City of Detroit officer. Later, another officer ticketed him for disorderly conduct. Hall filed two lawsuits: one against the City of Detroit and another against the officers, claiming retaliation for exercising his First Amendment rights. The district court consolidated the suits, denied Hall’s request to extend the discovery period, granted summary judgment to the City, but denied the ticketing officer’s claim of qualified immunity.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the City of Detroit, dismissing Hall’s claims against the City. However, the court denied the ticketing officer’s motion for summary judgment on the grounds of qualified immunity, allowing Hall’s First Amendment retaliation claim to proceed. Hall appealed the denial of his motion to extend the discovery period and the summary judgment in favor of the City, while the ticketing officer appealed the denial of qualified immunity.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s denial of Hall’s motion to extend the discovery period and the grant of summary judgment to the City. However, the appellate court reversed the district court’s decision denying the ticketing officer’s motion for summary judgment on the grounds of qualified immunity. The court held that the officer was entitled to qualified immunity because it was not clearly established that issuing a ticket under the circumstances violated Hall’s First Amendment rights. The court emphasized that the officer acted on plausible instructions from a superior and had no reason to doubt the legitimacy of the order. View "Hall v. Navarre" on Justia Law

The case involves Robert Holman, who challenged a debt-relief program under the American Rescue Plan Act that provided benefits to "socially disadvantaged" farmers and ranchers based on racial categories. Holman, a farmer, argued that he was excluded from the program solely due to his race and sought a preliminary injunction to halt the program. The district court granted the preliminary injunction, finding that the program did not meet the strict scrutiny standard required for racial classifications under the Fifth Amendment. However, before a final judgment was reached, Congress repealed the program, leading Holman to seek attorney's fees under the Equal Access to Justice Act (EAJA).The United States District Court for the Western District of Tennessee denied Holman's request for fees, ruling that he was not a "prevailing party" under the EAJA because the preliminary injunction did not provide him with lasting relief. The court also noted that the injunction was temporary and revocable, and thus did not materially alter the legal relationship between the parties.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court did not definitively rule on whether Holman was a "prevailing party" but found that the Government's position during the litigation was "substantially justified" under the EAJA. The court noted that the Government had presented substantial evidence to defend the program's constitutionality, including historical discrimination against minority farmers by the USDA. The court concluded that a reasonable person could find the Government's position justified, thereby precluding Holman's entitlement to attorney's fees and expenses. View "Holman v. Vilsack" on Justia Law

In this case, three plaintiffs—Christian Healthcare Centers, Sacred Heart of Jesus Parish, and St. Joseph Parish St. Johns—challenged aspects of Michigan’s antidiscrimination laws, alleging that these laws violated their First and Fourteenth Amendment rights. The plaintiffs argued that the laws chilled their speech and conduct, particularly regarding their religious beliefs and practices related to gender identity and sexual orientation.The United States District Court for the Western District of Michigan dismissed each case for lack of standing. The court reasoned that none of the plaintiffs had shown that Michigan’s laws arguably proscribed their speech or conduct, nor had they demonstrated a credible threat of enforcement against them. Consequently, the district court granted the defendants' motions to dismiss.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions. The appellate court agreed in part, finding that Michigan’s laws arguably forbade several of the plaintiffs’ pleaded activities. The court concluded that Christian Healthcare and Sacred Heart had plausibly established a credible threat of enforcement against them for some of the challenged provisions of Michigan’s laws. However, the court found that St. Joseph Parish had not plausibly established standing, as it failed to show a credible threat of enforcement.The Sixth Circuit affirmed the district court’s dismissal of the claims related to the Equal Accommodations Act (EAA) but reversed the dismissal of the claims related to the Elliot-Larsen Civil Rights Act (ELCRA) for Christian Healthcare and Sacred Heart. The court remanded the cases to the district court to evaluate the plaintiffs’ requests for injunctive relief. The district court’s decisions were thus affirmed in part, reversed in part, and remanded for further proceedings. View "Christian Healthcare Centers v. Nessel" on Justia Law

Kimberly Diei, a pharmacy student at the University of Tennessee Health Science Center, maintained social media accounts under a pseudonym where she posted about song lyrics, fashion, and sexuality. Her posts did not identify her as a student or affiliate her with the university. Despite this, the College of Pharmacy's Professional Conduct Committee investigated her social media activity following anonymous complaints. The Committee found her posts "sexual," "crude," and "vulgar," and ultimately voted to expel her. Diei appealed, and the Dean reversed the expulsion decision.Diei then filed a lawsuit in the United States District Court for the Western District of Tennessee, asserting violations of her First Amendment rights under 42 U.S.C. § 1983. She sought declaratory and injunctive relief, as well as damages for emotional distress. The district court dismissed her complaint, ruling that her claims for injunctive and declaratory relief were moot due to her graduation and that her remaining claims failed to state a claim for relief. The court also held that the defendants were entitled to qualified immunity.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court determined that Diei's claims for injunctive and declaratory relief were moot but found that her claims for damages were still viable. The court held that Diei plausibly alleged a First Amendment violation, as her social media posts were unrelated to her studies, caused no disruption, and were made under a pseudonym. The court also found that the district court improperly relied on documents not properly before it when dismissing Diei's complaint. The Sixth Circuit reversed the district court's dismissal of Diei's claims for damages and remanded the case for further proceedings, holding that Diei's speech was protected by the First Amendment and that the defendants were not entitled to qualified immunity at this stage. View "Diei v. Boyd" on Justia Law

A psychiatrist employed at a public university's medical school participated in a panel discussion on childhood gender dysphoria, expressing views that were unpopular with his colleagues and supervisors. Following his remarks, he was demoted and his contract was not renewed after over fifteen years of employment. He sued several university officials, alleging First Amendment retaliation.The United States District Court for the Western District of Kentucky denied the defendants' motions for summary judgment, which argued for Eleventh Amendment immunity and qualified immunity. The court found material fact disputes regarding whether the defendants retaliated against the plaintiff for his protected speech.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plaintiff's speech was protected under the First Amendment as it addressed a matter of public concern and was not made pursuant to his official duties. The court also found that the plaintiff's interest in speaking on the topic outweighed the university's interest in maintaining workplace efficiency. The court determined that the adverse actions taken against the plaintiff, including his demotion and contract nonrenewal, were motivated by his protected speech.The Sixth Circuit affirmed the district court's denial of summary judgment, concluding that the defendants were not entitled to Eleventh Amendment immunity or qualified immunity. The court held that the plaintiff's rights were clearly established and that a reasonable university official would have understood that retaliating against him for his speech was unlawful. The court also denied the plaintiff's motion to dismiss the appeal for lack of jurisdiction as moot. View "Josephson v. Ganzel" on Justia Law