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

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

Joseph Hehrer was detained in the Clinton County Jail in Michigan following charges related to operating a vehicle under the influence and a probation violation. While in custody, Hehrer began to exhibit symptoms of illness, including vomiting and abdominal pain. Over four days, jail medical staff evaluated him multiple times but failed to diagnose his underlying diabetes. Despite continued deterioration, corrections officers deferred to the medical professionals’ judgment and followed their instructions. Hehrer’s condition worsened until he was transported to a hospital, where he died from diabetic ketoacidosis.The United States District Court for the Western District of Michigan reviewed the estate’s claims, which included federal claims under 42 U.S.C. § 1983 against the county and its officers for deliberate indifference to medical needs, as well as a Monell claim for failure to train. The estate also brought state-law claims against the contracted medical provider and its staff. A magistrate judge recommended granting summary judgment to the county and its officials on the federal claims, finding no deliberate indifference or Monell liability, and advised declining supplemental jurisdiction over the state-law claims. The district court adopted these recommendations and entered final judgment for the defendants.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The Sixth Circuit held that the corrections officers acted reasonably by deferring to medical staff and did not act with deliberate indifference under the applicable Fourteenth Amendment standard. The court further held that the estate failed to show a pattern or obvious need for additional training to support Monell liability. Finally, the Sixth Circuit found no abuse of discretion in declining supplemental jurisdiction over the state-law claims after dismissing the federal claims. View "Hehrer v. County of Clinton" on Justia Law

An elected county commissioner was arrested during a public board meeting after she repeatedly interrupted the reading of a letter that criticized her prior statements about alleged inmate mistreatment in the county jail. The commissioner, known for her confrontational stance toward her fellow commissioners and county officials, objected to the letter being read without prior notice and continued to speak over the clerk despite warnings and calls to order from her colleagues. Two sheriff’s deputies present as security arrested her for disrupting a lawful meeting under an Ohio statute. She was processed and released the same day, and the criminal complaint was later dismissed.The United States District Court for the Northern District of Ohio granted partial summary judgment in favor of the commissioner on her federal claims for First Amendment retaliation and Fourth Amendment unlawful seizure, and denied qualified immunity and statutory immunity to the defendants on these claims and related state-law claims for false arrest and civil conspiracy. The defendants, including the deputies, fellow commissioners, and sheriff, appealed the denial of immunity.The United States Court of Appeals for the Sixth Circuit held that the deputies had probable cause to arrest the commissioner for disrupting the meeting, and thus all defendants were entitled to qualified immunity on the Fourth Amendment claim. The court also concluded that only the deputies were personally involved in the arrest for purposes of individual First Amendment liability and that the presence of probable cause generally precluded the First Amendment retaliatory arrest claim, but remanded for the district court to consider whether exceptions to this rule applied. Regarding the state-law claims, the court affirmed the denial of statutory immunity, finding genuine issues of material fact as to whether the defendants acted in bad faith by allegedly conspiring to arrest the commissioner in retaliation for her speech. The case was remanded for further proceedings. View "Frenchko v. Monroe" on Justia Law

A man seeking treatment for mental health issues voluntarily admitted himself to a hospital in Chattanooga, Tennessee. Medical staff determined he needed emergency medication and began to physically restrain him when he refused a shot. An off-duty police officer, working as a hospital security guard and wearing his police uniform, intervened. He twisted the patient's arm behind his back, and when the patient pulled away to relieve pain, the officer punched the patient’s head into a cinderblock wall, causing head trauma. The patient remained nonviolent throughout and was smaller in stature than those restraining him.Following the incident, the Chattanooga Police Department conducted an internal investigation. Opinions within the review process were divided, but the interim chief ultimately found no policy violation. The patient filed suit in the United States District Court for the Eastern District of Tennessee, alleging excessive force under 42 U.S.C. § 1983, multiple state-law torts, and municipal liability against the City for failing to train or supervise the officer. The district court granted summary judgment for the officer on all but the assault and battery claim, finding qualified immunity on the excessive force claim, and granted summary judgment for the City on all claims.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that, although a reasonable juror could find the officer’s use of force excessive under the circumstances, the law was not clearly established that an officer in this situation could not use such force. Therefore, the officer was entitled to qualified immunity. The court also found that the City was not liable under Monell since the plaintiff failed to demonstrate that a final policymaker’s actions were the moving force behind his injury. The district court’s judgment was affirmed. View "Guptill v. City of Chattanooga" on Justia Law

An attorney who chaired the Davidson County Election Commission was also employed at a law firm that represented the Metropolitan Government of Nashville and Davidson County. The Election Commission became involved in a dispute over whether a citizen-initiated tax-repeal referendum should be placed on the ballot, a measure opposed by the city government and certain city council members. The attorney, acting as commission chair, supported certifying the referendum. Following pressure from city officials, including a council member who threatened to withdraw city business from the law firm if the attorney continued supporting the referendum, the law firm terminated the attorney’s employment after he refused to change his position.The attorney filed suit in the United States District Court for the Middle District of Tennessee, asserting violations of his First Amendment rights under 42 U.S.C. § 1983, among other claims. The district court denied motions to dismiss based on qualified immunity filed by both the council member and the law firm. The court concluded that the council member’s alleged conduct violated clearly established First Amendment law and that the law firm, as a private entity, was not entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit determined that both the council member and the law firm were eligible to assert qualified immunity due to their public functions in this context. The court held that the council member was not entitled to qualified immunity because the complaint plausibly alleged he violated clearly established First Amendment rights by causing the attorney’s firing due to protected speech. However, the court found that the law firm was entitled to qualified immunity, as there was no clearly established law prohibiting a law firm from firing an employee in response to client pressure under these circumstances. Accordingly, the Sixth Circuit affirmed the denial of qualified immunity for the council member, reversed as to the law firm, and remanded for further proceedings. View "DeLanis v. Metropolitan Government of Nashville" on Justia Law

In this case, the petitioner was convicted by a Michigan state jury of first-degree murder, being a felon in possession of a firearm, and felony firearm. The homicide occurred in a Detroit neighborhood known for drug trafficking, where the victim was found with multiple gunshot wounds and no physical evidence tying any individual to the crime. Two witnesses, both local drug dealers, initially denied knowledge of the shooting but later identified the petitioner as the shooter after being arrested on unrelated charges. Their trial testimony was the primary evidence against the petitioner, as there was no physical evidence or eyewitness identification from the scene.Following his conviction, the petitioner pursued direct appeals and post-conviction relief through the Michigan courts, asserting ineffective assistance of counsel. Those efforts were unsuccessful. He then filed a federal habeas petition, which was denied. Years later, he sought state court relief again, now relying on an affidavit from another individual who claimed to have witnessed the murder and identified a different perpetrator. The state trial court rejected this new evidence as unreliable and insufficient to overcome procedural barriers, and subsequent appeals in the state courts were denied. The petitioner returned to federal court with a second habeas petition, presenting affidavits including recantations and new claims of innocence. The U.S. District Court for the Eastern District of Michigan dismissed the petition, finding it untimely and failing to meet the stringent requirements for successive habeas petitions.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. It agreed that the petitioner did not satisfy the gatekeeping requirements for successive petitions under 28 U.S.C. § 2244(b)(2)(B), nor did he establish grounds for equitable tolling based on actual innocence. The Sixth Circuit held that the new affidavits presented were unreliable and would not clearly and convincingly prevent any reasonable juror from convicting the petitioner. The court affirmed the district court’s dismissal of the habeas petition. View "Houston v. Tanner" on Justia Law