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

Johnathan Holt, just weeks before his eighteenth birthday, shot and killed a drug dealer, Quincy Battle, on behalf of the Short North Posse gang. Holt was later paralyzed from the chest down due to gun violence. A federal jury convicted him of murder in aid of racketeering and murder with a firearm during a drug-trafficking crime. The district court initially sentenced him to life imprisonment, but this was later vacated as it violated the Eighth Amendment under Miller v. Alabama, which prohibits mandatory life sentences for juveniles. Holt was resentenced to 900 months in prison.The United States District Court for the Southern District of Ohio initially sentenced Holt to life imprisonment, which was later vacated due to the Eighth Amendment violation. The district court then resentenced him to 900 months in prison. Holt appealed, arguing that his new sentence still violated the Eighth Amendment and was procedurally and substantively unreasonable.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court had adequately considered Holt’s youth, as required by Miller v. Alabama, and that the Eighth Amendment did not require a more lenient sentence based on his medical condition. The court also found that Holt’s procedural claims, including the district court’s handling of the presentence report and his right to allocute, did not demonstrate plain error. Finally, the court held that the 900-month sentence was substantively reasonable given the severity of Holt’s crime and the district court’s consideration of the relevant sentencing factors. The Sixth Circuit affirmed the district court’s decision. View "United States v. Holt" on Justia Law

The plaintiffs, including the National Republican Senatorial Committee, National Republican Congressional Committee, Senator J.D. Vance, and former Representative Steve Chabot, challenged the Federal Election Campaign Act’s limits on coordinated campaign expenditures. They argued that these limits, which restrict political parties from spending money on campaign advertising with input from the candidate, violate the First Amendment. The plaintiffs sought declaratory and injunctive relief to prevent the Federal Election Commission from enforcing these limits, claiming that the restrictions increase costs, create redundancies, and hinder effective communication and spending.The United States District Court for the Southern District of Ohio certified the constitutional question to the United States Court of Appeals for the Sixth Circuit. The district court found that the plaintiffs raised a non-frivolous question and established a factual record before certifying the question. The district court asked whether the limits on coordinated party expenditures in the Federal Election Campaign Act violate the First Amendment, either on their face or as applied to party spending in connection with "party coordinated communications."The United States Court of Appeals for the Sixth Circuit reviewed the case en banc. The court held that the Supreme Court’s 2001 decision in FEC v. Colorado Republican Federal Campaign Committee (Colorado II) remains binding and that the Act’s limits on coordinated party expenditures do not facially violate the First Amendment. The court rejected the plaintiffs' arguments that changes in legal doctrine, statutory amendments, and factual developments since 2001 undermined Colorado II. The court also denied the plaintiffs' as-applied challenge, noting that it was too broad and would effectively nullify Colorado II. The court concluded that the limits on coordinated party expenditures do not violate the First Amendment, either on their face or as applied to party spending in connection with "party coordinated communications." View "National Republican Senatorial Committee v. Federal Election Commission" on Justia Law

Three Kentucky Republican Party county executive committees challenged the Kentucky Registry of Election Finance’s prohibition on expending funds to support a state constitutional amendment on the November general election ballot. The committees sought an advisory opinion from the Registry, which concluded that they could not use funds raised for party nominees to support a constitutional amendment and would need to form a political issues committee for such expenditures. The committees argued that this restriction violated their First Amendment rights.The United States District Court for the Eastern District of Kentucky denied the committees' motion for a preliminary injunction, finding that the requirement to form a political issues committee imposed only a minimal burden on their First Amendment rights, justified by the governmental interest in transparency and disclosure. The court concluded that the Registry’s actions met the standards of strict scrutiny, exacting scrutiny, or rational basis review.The United States Court of Appeals for the Sixth Circuit reviewed the case and granted an injunction pending appeal. The court found that the executive committees were likely to succeed on the merits of their First Amendment claim. It determined that the Registry’s prohibition on spending in support of a constitutional amendment burdened the committees' political speech. The court applied strict scrutiny, concluding that the Registry’s restriction was not narrowly tailored to the asserted interest in disclosure. The court noted that less restrictive alternatives, such as imposing disclosure requirements on executive committees, could achieve the same ends without restricting speech. The Registry was enjoined from enforcing its advisory opinion against the committees, and expedited briefing was ordered for the appeal. View "Boone County Republican Party Executive Committee v. Wallace" on Justia Law

James Conn murdered Savannah Puckett, and his parents, Mollie and Michael Slaybaugh, suffered property damage when police arrested Conn at their home. The Slaybaughs filed a lawsuit under 42 U.S.C. § 1983, seeking compensation for the damage under the Takings Clause of the Fifth Amendment and its Tennessee Constitution counterpart.The United States District Court for the Middle District of Tennessee dismissed the Slaybaughs' claims. The court ruled that the police actions did not constitute a taking for public use under the Fifth Amendment because the damage occurred while enforcing criminal laws. The court also dismissed the state-law claim, stating that the Tennessee Constitution offers protections co-extensive with the Fifth Amendment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the Slaybaughs did not state a valid takings claim because the police actions were privileged under the search-and-arrest privilege. This privilege allows law enforcement to use reasonable force to enter property and make an arrest without being liable for resulting property damage, provided the actions are lawful and reasonable. The court found no evidence suggesting the police acted unlawfully or unreasonably. Consequently, the court affirmed the district court's dismissal of both the federal and state constitutional claims. View "Slaybaugh v. Rutherford County" on Justia Law

In 2022, two top officers of the Libertarian Party of Michigan resigned, leading to a power struggle within the party. Andrew Chadderdon became the acting Chair, but his leadership was contested by the defendants, who then voted to remove him and elected themselves to committee positions. The Libertarian Party Judicial Committee later voided these elections, reinstating Chadderdon. The defendants, however, continued to use the Libertarian National Committee’s (LNC) trademark, claiming to be the rightful leaders of the Michigan affiliate.The United States District Court for the Eastern District of Michigan granted the LNC’s request for a preliminary injunction, barring the defendants from using the LNC’s trademark. The defendants appealed, arguing that the district court’s application of the Lanham Act to their noncommercial speech violated the First Amendment and that their use of the trademark was authorized and not likely to cause confusion.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Lanham Act could apply to the defendants’ use of the LNC’s trademark because they used it as a source identifier for their political services, which falls within the scope of the Act. The court also determined that the defendants’ use of the trademark created a likelihood of confusion among potential voters, party members, and donors. However, the court found that the defendants’ use of the trademark for online solicitation, when accompanied by clear disclaimers, did not create a likelihood of confusion.The Sixth Circuit affirmed the preliminary injunction in part, except for the aspect concerning the defendants’ online solicitation with disclaimers, which it vacated. View "Libertarian National Committee, Inc. v. Saliba" on Justia Law

Nicholas Somberg, an attorney in Michigan, was representing a criminal defendant in the 52nd Judicial District. During a virtual courtroom conference, Somberg took a picture of the Zoom meeting without the judge's permission and posted it on Facebook. The Oakland County Prosecutor filed a motion to hold Somberg in contempt for violating Michigan court rules that prohibit recording or broadcasting judicial proceedings without permission. The court dismissed the motion on procedural grounds without addressing the rule's merits. Somberg, fearing future contempt actions, sued the prosecutor, seeking a declaration that the rule violates the First Amendment and an injunction to prevent its enforcement against him.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the prosecutor, concluding that the Electronics Rule satisfied First Amendment scrutiny. Somberg appealed the decision, arguing that the rule infringes on his constitutional rights.The United States Court of Appeals for the Sixth Circuit reviewed the case and focused on the issue of standing. The court held that Somberg lacked Article III standing to pursue his claim because he could not demonstrate causation and redressability. The court noted that even if the prosecutor were enjoined from seeking contempt sanctions, the court itself could still hold Somberg in contempt sua sponte. Additionally, third parties could refer Somberg for contempt proceedings. Therefore, the court concluded that the prosecutor was not the cause of Somberg's asserted future injury, and an injunction against her would not redress that injury. The court vacated the district court's order and remanded with instructions to dismiss the case for lack of jurisdiction. View "Somberg v. McDonald" on Justia Law

Victor S. Couzens, the senior pastor of Inspirational Bible Church (IBC), faced a significant decline in church membership and financial troubles following public accusations of an adulterous relationship. In response, church leaders organized a vote to remove him from his position. To enforce this decision, they hired off-duty police officers for the next Sunday service. When Couzens attempted to address the congregation, the officers threatened him with arrest, leading him to leave the church. Couzens subsequently sued the officers, their police chief, and the City of Forest Park, alleging a conspiracy to deny him his constitutional rights.The United States District Court for the Southern District of Ohio granted summary judgment in favor of the defendants. The court found that while the officers' actions could be seen as a seizure under the Fourth Amendment, their actions were not unreasonable. The court also determined that the free exercise claim failed because the police department's policy did not target religious conduct. Without constitutional violations from individual defendants, the court found no merit in the municipal liability and civil conspiracy claims.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 the officers' actions were objectively reasonable given the circumstances and the evidence they had, including a letter indicating Couzens' removal as pastor. The court also found that Couzens failed to establish a violation of his First Amendment rights, as the officers' actions did not reflect state interference in church governance. Consequently, the court upheld the summary judgment on the constitutional, civil conspiracy, and municipal liability claims. View "Couzens v. City of Forest Park, Ohio" on Justia Law

Two young African American boys died in a house fire after two City of Flint firefighters failed to properly search the home. The then-City Fire Chief, Raymond Barton, attempted to discharge the firefighters for gross misconduct. However, Flint’s Mayor, Sheldon Neeley, allegedly intervened to cover up the firefighters' actions to gain support from the firefighters’ union for his re-election. When Barton refused to comply with Neeley’s directives to alter official reports and make false public statements, Neeley fired him.In the United States District Court for the Eastern District of Michigan, Barton filed a lawsuit claiming that his termination was retaliation in violation of his First Amendment rights. The district court denied Neeley’s motion to dismiss based on qualified immunity, leading to this interlocutory appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Barton plausibly alleged a violation of his First Amendment rights, as public employees cannot be compelled to make false, politically motivated statements on matters of public concern in response to threats of retaliation. The court affirmed the district court’s denial of qualified immunity to Neeley, concluding that Barton’s refusal to alter reports and make false statements was protected speech, and that it was clearly established that such compelled speech and retaliation violated the First Amendment. View "Barton v. Neeley" on Justia Law

Erick Williams was stopped by Memphis police for speeding and erratic driving. Officers smelled marijuana and saw an open beer can, leading them to search the car after a canine alert. They found a loaded pistol in the trunk. Williams, a convicted felon for aggravated robbery, was indicted for being a felon in possession of a firearm under 18 U.S.C. § 922(g)(1). He moved to dismiss the indictment, arguing that the statute violated the Second Amendment. The district court denied his motion, and Williams pled guilty while reserving the right to appeal.The United States District Court for the Western District of Tennessee denied Williams's motion to dismiss the indictment. Williams then appealed to the United States Court of Appeals for the Sixth Circuit, arguing that § 922(g)(1) was unconstitutional both on its face and as applied to him.The United States Court of Appeals for the Sixth Circuit reviewed the case and upheld the district court's decision. The court held that § 922(g)(1) does not violate the Second Amendment. The court reasoned that historical precedent supports the disarmament of individuals deemed dangerous, and Williams's criminal record, including convictions for aggravated robbery and attempted murder, demonstrated that he was dangerous. Therefore, the statute was constitutional as applied to him. The court also noted that while individuals must have an opportunity to show they are not dangerous, Williams failed to do so. The court affirmed the district court's decision, maintaining Williams's conviction under § 922(g)(1). View "United States v. Williams" on Justia Law

In this case, DEA agents, acting on an anonymous tip, conducted a four-month investigation into Robert Cortez Burrell's alleged drug trafficking activities. They surveilled Burrell, observed suspicious behavior consistent with drug transactions, and corroborated the tip with additional evidence, including Burrell's criminal history and interactions with known drug dealers. Based on this information, they obtained and executed search warrants for four residences associated with Burrell, recovering significant quantities of illegal narcotics, firearms, and drug-manufacturing equipment. Burrell was subsequently convicted by a jury of multiple drug-related offenses and being a felon in possession of firearms and ammunition, resulting in a 180-month prison sentence.The United States District Court for the Eastern District of Michigan denied Burrell's motion to suppress the evidence obtained from the searches, as well as his motion to dismiss the firearms and ammunition charges on Second Amendment grounds. The court found that the search warrants were supported by probable cause and that Burrell's motion to dismiss was untimely. Additionally, the court admitted testimony that Burrell argued violated the Confrontation Clause and the Federal Rules of Evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the search warrants were supported by probable cause, as the DEA agents had sufficiently corroborated the anonymous tip through extensive surveillance and other investigative methods. The court also found that the district court did not abuse its discretion in denying Burrell's motion to dismiss as untimely and that Burrell's constitutional challenges to the firearms and ammunition charges failed under the plain-error standard. Furthermore, the court ruled that the admission of the contested testimony did not violate the Confrontation Clause or the Federal Rules of Evidence, as the statements were not offered for their truth but to explain the DEA's actions. View "United States v. Burrell" on Justia Law