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

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

Joseph Fortin applied for disability insurance benefits, but his claim was denied by an Administrative Law Judge (ALJ) from the Social Security Administration (SSA). Fortin argued that the ALJ who denied his claim was improperly appointed because the then-Acting Commissioner of the SSA, Nancy Berryhill, lacked the authority to ratify the ALJ's appointment. Fortin did not challenge the merits of the ALJ's decision but focused on the validity of the ALJ's appointment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Commissioner of Social Security, rejecting Fortin's arguments. The court held that Berryhill's ratification of the ALJ's appointment was valid and that the ALJ did not err in denying Fortin's application for benefits.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Berryhill, as Acting Commissioner, had the authority to ratify the appointments of SSA ALJs in response to the Supreme Court's decision in Lucia v. Securities and Exchange Commission, which required ALJs to be appointed in accordance with the Appointments Clause. The court also concluded that Berryhill's actions were valid under the Federal Vacancies Reform Act and that she did not need to be reappointed by the sitting President to serve as Acting Commissioner. The court found that Berryhill's ratification of the ALJ's appointment was both constitutionally and statutorily valid, and therefore, Fortin was not entitled to a new hearing before a different ALJ. View "Fortin v. Commissioner of Social Security" on Justia Law

In 2020, Eric Noble, a security guard at the Cincinnati and Hamilton County Public Library, shared an insensitive meme on his personal Facebook page during the Black Lives Matter (BLM) protests. The meme, which was visible only to his Facebook friends, was taken down within 24 hours after his mother advised him to do so. However, some of his colleagues at the Library saw the post and complained. Following an investigation, the Library terminated Noble's employment, citing a violation of its harassment policy and a loss of confidence in his ability to perform his duties impartially.The United States District Court for the Southern District of Ohio granted summary judgment in favor of the defendants, holding that the Library's actions did not violate Noble's First Amendment rights as a public employee. Noble appealed the decision, arguing that his termination was a result of exercising his right to free speech.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Noble's Facebook post was protected speech under the First Amendment. The court found that Noble spoke on a matter of public concern and that his interest in expressing his views outweighed the Library's interest in maintaining workplace efficiency. The court noted that there was no evidence of public disruption or that Noble's post had a significant impact on Library operations. Consequently, the court remanded the case with instructions to grant summary judgment in favor of Noble on his First Amendment retaliation claim. View "Noble v. Cincinnati & Hamilton County Public Library" on Justia Law

The plaintiffs, who regularly engage in cryptocurrency transactions, challenged amendments to 26 U.S.C. § 6050I, which now require reporting certain cryptocurrency transactions to the federal government. They argued that the law violates their constitutional rights under the Fourth, First, and Fifth Amendments, and exceeds Congress's enumerated powers. The plaintiffs claimed that the law's requirements would force them to disclose private information, incur compliance costs, and potentially expose them to criminal penalties.The United States District Court for the Eastern District of Kentucky dismissed the case, finding that it lacked jurisdiction to consider the merits of the plaintiffs' claims. The court ruled that the claims were either not ripe for adjudication or that the plaintiffs lacked standing. Specifically, the court found that the Fourth Amendment claim was not ripe because the law was not yet effective and the Department of Treasury was still developing rules. The First Amendment claim was dismissed for lack of standing, as the court deemed the plaintiffs' injuries too speculative. The court also found the Fifth Amendment vagueness claim unripe due to pending regulatory action, and the enumerated-powers claim unripe for similar reasons. The Fifth Amendment self-incrimination claim was dismissed as not ripe because the plaintiffs had not yet asserted the privilege.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the district court erred in dismissing the enumerated-powers, Fourth Amendment, and First Amendment claims. The appellate court held that these claims were ripe for review and that the plaintiffs had standing. The court noted that the plaintiffs, as direct objects of the law, would indeed be subject to the reporting requirements and incur compliance costs, thus suffering an injury in fact. The court affirmed the district court's dismissal of the Fifth Amendment vagueness and self-incrimination claims as not ripe. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Carman v. Yellen" on Justia Law

Nathaniel Jackson was convicted of a capital offense and sentenced to death. His sentencing was marred by judicial bias and misconduct, including ex parte communications between the judge and prosecutor and the prosecutor ghostwriting the judge’s sentencing opinion. When this misconduct was revealed, the Ohio appellate courts ordered new sentencing proceedings. However, the trial judge denied Jackson’s motion to present additional mitigating evidence and resentenced him based on the old record, issuing a nearly identical opinion to the original one.The Ohio appellate courts affirmed Jackson’s sentence despite the trial judge’s misconduct. Jackson then filed a habeas corpus petition in federal district court. The district court granted the petition on the grounds that Jackson was unconstitutionally denied the opportunity to present mitigating evidence but denied his other claims, including judicial bias.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Ohio’s standard for assessing judicial bias was contrary to clearly established federal law. On de novo review, the court found that the trial judge was unconstitutionally biased. The court also held that the exclusion of mitigating evidence at Jackson’s resentencing violated the Eighth Amendment, as capital defendants have the right to present all relevant mitigating evidence. Consequently, the court affirmed the district court’s issuance of a writ of habeas corpus on the mitigating-evidence claim, reversed the denial on the judicial-bias claim, and remanded for further proceedings. View "Jackson v. Cool" on Justia Law

Marc Susselman received a traffic ticket from a Washtenaw County Sheriff’s deputy for failing to yield to a police cruiser with flashing lights. This ticket was later dismissed, but Susselman received another citation for failing to obey a police officer directing traffic. The Michigan circuit court ultimately dismissed the second ticket as well. Susselman then filed a federal lawsuit asserting constitutional and state law claims against Washtenaw County, the Washtenaw County Sheriff’s Office, the sheriff’s deputy, and Superior Township, Michigan.The United States District Court for the Eastern District of Michigan granted the defendants' motions to dismiss all claims. Susselman appealed the decision. The district court had found that the Washtenaw County Sheriff’s Office could not be sued under 42 U.S.C. § 1983 and that Susselman had waived certain state-law claims. The court also dismissed Susselman’s federal claims, including First Amendment retaliation and Fourteenth Amendment malicious prosecution, as well as state-law claims for malicious prosecution and intentional infliction of emotional distress.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court held that Susselman failed to plausibly allege a constitutional violation or behavior by the deputy that would support his claims. Specifically, the court found that the issuance of the second ticket did not constitute a violation of substantive due process or First Amendment rights. Additionally, the court determined that Susselman did not establish a civil conspiracy or meet the requirements for his state-law claims. The court also concluded that Susselman did not identify any municipal policy or custom that resulted in a constitutional violation, thus dismissing his claims against Washtenaw County and Superior Township. View "Susselman v. Washtenaw County Sheriff's Office" on Justia Law

A group of parents, represented by Parents Defending Education (PDE), challenged the Olentangy Local School District's policies that prohibit harassment based on gender identity, including the intentional use of non-preferred pronouns. PDE argued that these policies violated the First Amendment's Free Speech Clause. The policies in question include the Anti-Harassment Policy, the Personal Communication Devices (PCD) Policy, and the Code of Conduct, all of which aim to prevent harassment and bullying within the school district.The United States District Court for the Southern District of Ohio denied PDE's motion for a preliminary injunction to prevent the enforcement of these policies. The court found that PDE had not demonstrated a likelihood of success on the merits of their First Amendment claims. Specifically, the court held that the policies did not unconstitutionally compel speech, did not constitute viewpoint discrimination, and were not overbroad. The court also determined that PDE had not shown that the policies would likely cause irreparable harm.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that PDE had not met the burden of showing a clear likelihood of success on the merits. The court found that the school district's policies were consistent with the standard for regulating student speech established in Tinker v. Des Moines Independent Community School District, which allows schools to regulate speech that could substantially disrupt school activities or invade the rights of others. The court also held that the policies did not unconstitutionally compel speech, as students could use first names instead of pronouns, and that the policies were not overbroad. The court concluded that PDE had not demonstrated that the balance of equities or the public interest favored granting a preliminary injunction. View "Parents Defending Education v. Olentangy Local School District" on Justia Law

In September 2018, Bryana Baker was arrested and taken to Butler County Jail, where she began experiencing drug withdrawal symptoms. After attempting to escape, she was placed in disciplinary isolation. Despite multiple mental health assessments indicating she was not suicidal, Baker was placed on suicide watch due to erratic behavior. On September 24, she was removed from suicide watch but was not cleared for single-celling. The next day, after a series of altercations with her cellmate, Officer April Riahi closed Baker’s cell door. Shortly thereafter, Baker was found hanging in her cell and later died.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants, including Officer Riahi, Sheriff Richard Jones, and Butler County. The court found no evidence of deliberate indifference or constitutional violations by the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that Officer Riahi was entitled to qualified immunity because no clearly established law indicated her actions were unconstitutional. The court also found that Sheriff Jones could not be held liable under supervisory liability since there was no underlying constitutional violation by Riahi. Additionally, the court ruled that Butler County was not liable under municipal liability theories because there was no deliberate indifference to a clearly established right. Lastly, the court determined that Riahi and Jones were entitled to Ohio statutory immunity on the state-law claims, as their actions did not amount to recklessness under Ohio law.The Sixth Circuit affirmed the district court’s judgment, granting summary judgment to the defendants on all claims. View "Campbell v. Riahi" on Justia Law