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

Plaintiffs, Catholic Church-affiliated entities, have religious objections to the Patient Protection and Affordable Care Act, 42 U.S.C. 300gg-13, requirement that their employer-based health insurance plans cover all FDA-approved contraception, sterilization methods, and counseling. All are eligible for either an exemption or an accommodation, through which the entities will not pay for the contraceptive products and services and the coverage will be independently administered by a third-party. Nonetheless, they alleged that the contraceptive-coverage requirement violated the Religious Freedom Restoration Act and the Free Speech, Free Exercise, and Establishment Clauses. District courts preliminary injunctions. The Sixth Circuit affirmed, finding that the plaintiffs did not demonstrate a strong likelihood of success on the merits and, therefore, did not demonstrate that they would suffer irreparable injury without the injunction. In the subsequent Hobby Lobby decision, in which the Supreme Court discussed the accommodation favorably, noting that the accommodation served the government’s interests in providing access to contraception while at the same time not impinging on the religious beliefs of objecting non-profits. After reviewing the Hobby Lobby opinion, the Sixth Circuit affirmed original disposition, holding that the accommodation provision does not violate RFRA. View "Mich. Catholic Conference v. Burwell" on Justia Law

In 2000, Davis was engaged to Jennifer, who had an eight-month old son, Caine. Davis was not Caine’s father. On January 27, Davis was at Jennifer’s apartment. Caine was fussy. Davis grew frustrated and pushed Caine across the floor. Later, Jennifer left Davis to watch Caine. When she called to ask about Caine, Davis said that something was wrong. Chilton asked a friend to check on Caine. Her friend found Caine limp. His pulse was weak and erratic, his eyes were rolled back and he was not breathing. Caine was airlifted to Vanderbilt Medical Center where doctors found three complex skull fractures, massive internal bleeding, retinal bleeding in both eyes, and a torn membrane between the lip and the gums. Caine died. Davis insisted he had not dropped Caine and claimed to have no idea how he was injured. Outside a neighbor’s apartment, police found a bag containing a wet washcloth and Caine’s shirt. Davis admitted that he had used the rag to wipe blood out of Caine’s mouth. At trial, in contrast to his previous claims, Davis testified that he had dropped Caine accidentally. A medical expert testified that Caine’s injuries were consistent with that testimony; he eventually lost his medical license for misleading testimony in other trials. All of the doctors who had treated Caine testified that his death could not have been an accident. Following a mistrial, Davis was unable to find an expert willing to take the case. The jury convicted him of felony murder and aggravated child abuse. Davis exhausted state remedies The Sixth Circuit affirmed denial of his petition for federal habeas relief in which he argued ineffective assistance. View "Davis v. Carpenter" on Justia Law

Keys was convicted in 2005 of second-degree murder, conspiracy to commit unarmed robbery, and assault with the intent to rob while armed. Due in part to his “habitual offender” status, the Michigan state court sentenced Keys to life in prison for the murder and conspiracy charges and to 12 to 25 years of imprisonment for the assault charge (to be served concurrently). Following the exhaustion of his state-court remedies, Keys filed a federal petition for habeas corpus. The Sixth Circuit affirmed denial of the petition, rejecting arguments that the prosecution failed to present evidence sufficient to support convictions for second-degree murder and assault with the intent to rob while armed; that Keys’ due process rights were violated when the jury panel viewed him in shackles during voir dire; and that Keys’ counsel on direct appeal was constitutionally ineffective for failing to fully investigate and raise the shackling claim. View "Keys v.Booker" on Justia Law

The facts are based on video footage and Officer Byrd’s deposition. Byrd was on bicycle patrol in Elsmere, Kentucky, at 1:00 a.m. A Finish Line Bar employee approached, concerned about a man (Godawa) in the parking lot. Godawa got into a vehicle and drove around the parking lot. Byrd approached and saw a beer in the cup holder. Godawa stated that his driver’s license was not with him; declined to take a sobriety test; provided identifying information; admitted that he had consumed alcohol; then agreed to a field sobriety test. Byrd went to his bicycle to request backup. Godawa started his vehicle and began to back out of the parking spot, hitting the bicycle. Byrd yelled “Stop” multiple times, and had his gun drawn as he ran to the front of Godawa’s car. Byrd and Godawa’s car apparently came into contact—how it happened is disputed. Byrd got up and ran alongside the vehicle before shooting through the rear passenger-side window, hitting Godawa. Godawa drove away, turned around, and drove back. Byrd was in the middle of Dixie Highway with his gun drawn. He observed that Godawa was “slumped over.” Godawa’s vehicle struck a utility pole. Godawa subsequently died from the gunshot wound. The court dismissed the estate’s 42 U.S.C. 1983 excessive force claims. The Sixth Circuit reversed, finding that Byrd was not entitled to qualified immunity. A genuine dispute of material fact exists regarding the circumstances of Byrd’s impact with Godawa’s vehicle; a reasonable juror could conclude that Byrd’s use of deadly force violated Godawa’s clearly established constitutional rights. View "Godawa v. Byrd" on Justia Law

Kindl’s breathalyzer test revealed a blood alcohol level of .053. She was arrested for violating a condition of probation that she refrain from alcohol use. The video recording of her booking shows Kindl stating that she “might have a little alcohol withdrawal.” Kindl was placed in cell one, which was subject to video (not sound) monitoring and direct visual observation by the front desk. After an uneventful afternoon, Kindl’s condition deteriorated. At 7:46 p.m., the video shows her body jerking dramatically in an apparent seizure. Around 8 p.m., Kindl tried to communicate with the officers. She knocked on the window four different times, repeatedly calling out. Kindl eventually spoke to two officers, stating that she had urinated on herself and that she was concerned about delirium tremens. According to the officers, she stated that she did not currently have symptoms. Kindl lay back down, intermittently experiencing convulsions, and calling out. At 11:53 p.m., she experienced a violent 40-second seizure. She did not move again. Six hours later, Kindl’s body was discovered. A pathologist determined that Kindl died of delirium tremens. Both officers testified that they were aware that alcohol withdrawal could be a serious condition, but that they never saw Kindl in physical distress. The court ruled that 42 U.S.C. 1983 claims of deliberate indifference, gross negligence and intentional infliction of emotional distress could proceed against the officers, dismissed other claims, and denied the officers’ claims to qualified immunity. The Sixth Circuit dismissed an appeal, noting disputed facts. View "Kindl v. City of Berkley" on Justia Law

In 1993, Muslim inmates seized control of cellblock “L” at the Southern Ohio Correctional Facility, took guards hostage and locked inmates considered “snitches” into cells in the L–6 section. The Muslim inmates maintained control of unit L–6 while the Aryan Brotherhood and the Black Gangster Disciples controlled other units within L–Block. LaMar an SOCF inmate serving a sentence for a 1989 murder conviction, was not a Muslim, did not plan or participate in the prison takeover and was in the prison recreation yard when the riot began. LaMar and other inmates negotiated with the Muslim inmates and beat to death five inmates, identified as “snitches,” in exchange for access to the yard. Convicted, LaMar received death sentences for four of the killings and a life sentence for the fifth. After exhausting state remedies, LaMar’s federal habeas petition was rejected. The Sixth Circuit affirmed, rejecting claims that the state withheld favorable evidence in violation of Brady v. Maryland; that the state trial court denied LaMar due process by refusing to sever one count from the remaining charges; that there was insufficient evidence for one of the capital sentencing aggravators; and that he was denied due process by prosecutorial misconduct. View "LaMar v. Houk" on Justia Law

Three-month-old Jiyen was killed when 11 shots were fired into his home in a drive-by shooting. Prosecution witnesses testified to overhearing Drummond discussing a retribution for the death of a fellow gang member, seeing Drummond with an assault rifle 15 minutes before the fatal shots were fired, and to hearing Drummond say that “he didn’t meant [sic] to kill the baby.” A search of Drummond’s house yielded ammunition consistent with the shooting and items tying him to the gang. During trial, the court twice closed the courtroom, once stating that witnesses felt threatened by some of the spectators. A jury found Drummond guilty; the trial court sentenced Drummond to death. The Supreme Court of Ohio affirmed on direct appeal. State courts denied post-conviction relief. A federal district court granted habeas corpus, holding that the court violated Drummond’s Sixth Amendment right to a public trial. The Sixth Circuit initially affirmed, but later reversed, distinguishing Supreme Court precedent that involved a full courtroom closure, while Drummond had a partial closing. For a partial closing, the court must balance the interests. The Ohio courts applied that principle reasonably, in the capacious sense of “reasonable” as used for purposes of the habeas statute. View "Drummond v. Houk" on Justia Law

Simmons and 20 others were indicted for conspiracy to sell cocaine, 21 U.S.C. 841(a)(1) and 846. During Simmons’s trial, the government moved to exclude three of Simmons’s co-defendants from the courtroom during the testimony of one of its witnesses, arguing that, due to certain comments made by Simmons and other individuals outside the courtroom, the presence of the three co-defendants might make the witness feel uncomfortable and intimidated even though the government conceded that none of the statements were threatening and that it did not know whether they were made by any of the three co-defendants it sought to exclude. The district court granted the motion, reasoning that it had discretion to bar any individual from the courtroom if there were any possibility that his or her presence might be intimidating The Sixth Circuit reversed, holding the district court violated Simmons’s Sixth Amendment right to a public trial when it excluded the three co-defendants from the courtroom without making factual findings that adequately support its decision. View "United States v. Simmons" on Justia Law

Clay, diagnosed with schizophrenia and bipolar disorder, spoke on the phone with his caseworker, who called Hazel Park Police to report that Clay told her he planned to commit suicide and that Clay had attempted suicide in the past and had been repeatedly hospitalized. Officer Emmi and paramedics were dispatched. Clay was found hiding in a minivan in the driveway. He got into the ambulance voluntarily and walked to the emergency department and was placed in a curtained-off area without handcuffs and without incident. Clay would not put on the hospital gown. He was taken to the floor and handcuffed. At some point Emmi used his Taser on Clay’s back, Clay was lifted and restrained to a hospital bed. He tested positive for cocaine and marijuana. Emmi claims that Clay tried to leave after being told to put the gown on, that he was “flailing,” and was placed in restraints only after Emmi warned him that a Taser would be applied. In Clay’s action under 42 U.S.C. 1983, the Sixth Circuit affirmed that the Fourth Amendment applied because the force was used in the context of a seizure, and that Emmi was not entitled to qualified immunity because there was a genuine dispute of material fact about the amount of force used. View "Clay v. Emmi" on Justia Law

In 1996 (Free Press I), the Sixth Circuit held that the Freedom of Information Act, 5 U.S.C. 552, requires government agencies to honor requests for the booking photographs of criminal defendants who have appeared in court during ongoing proceedings. Despite that holding, the U.S. Marshals Service denied the Free Press’s 2012 request for the booking photographs of Detroit-area police officers indicted on federal charges. The district court, bound by Free Press I, granted summary judgment to the newspaper in the ensuing lawsuit. A Sixth Circuit panel affirmed, while urging the full court to reconsider the merits of Free Press I. The court noted FOIA Exemption 7(C) which protects a non-trivial privacy interest in keeping “personal facts away from the public eye,” and that individuals do not forfeit their interest in maintaining control over information that has been made public in some form. Criminal defendants do not forfeit their interest in controlling private information while their cases remain pending. View "Detroit Free Press, Inc v. Dept. of Justice" on Justia Law