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

In 2017, Quintanilla pleaded guilty to conspiring to distribute and possess with intent to distribute and possessing with intent to distribute five kilograms or more of cocaine and illegally reentering the U.S. after having been removed subsequent to a felony conviction. He was sentenced to 120 months’ imprisonment and did not appeal. In April 2020, Quintanilla sought compassionate release under 18 U.S.C. 3582(c)(1)(A). Court-appointed counsel asserted that Quintanilla has underlying medical conditions that put him at high risk, including diabetes, obesity, and hypertension; that his facility, FCI Oakdale, was among those hardest hit by the pandemic; and that the 18 U.S.C. 3553(a) factors weighed in favor of release. The government argued that he had not demonstrated sufficiently extraordinary and compelling reasons and that he is a danger to the community, so his release would be inconsistent with section 3553(a).The district court denied the motion, stating on a form order that it had considered the applicable section 3553(a) factors and policy statements and conducted a “complete review” of the merits. The Sixth Circuit affirmed. Quintanilla’s request for compassionate release and the denial thereof reflects a “conceptually simple” matter suitable to resolution via a form order; the district court did not abuse its discretion by denying Quintanilla’s motion. View "United States v. Quintanilla-Navarro" on Justia Law

In 1975, schoolteacher and drug dealer Ingram was robbed and shot dead in her Detroit home. Watkins’s 20-year-old high school classmate, Herndon, testified that he and Watkins robbed and murdered Ingram together. Detroit Evidence Technician Badaczewski testified that a hair found on Ingram’s clothing matched Watkins's hair sample. After Watkins’s conviction, Herndon repeatedly recanted. In sworn affidavits, letters, and testimony, Herndon attested that Wayne County Prosecutor Healy and Detective Schwartz threatened to charge him with Ingram’s murder and another murder if Herndon did not implicate Watkins and testify at Watkins’s trial. Watkins’s efforts to overturn his conviction had no success for four decades.In 2017, Watkins presented new evidence that Badaczewski’s hair analysis methods were seriously flawed. The Michigan court dismissed the case against Watkins without prejudice. Months later, Watkins filed a 42 U.S.C. 1983 suit against Healy, Schwartz's estate, Badaczewski, and Detroit.The district court denied Healy’s motion to dismiss. The Sixth Circuit found that it lacked jurisdiction to consider most of Healy’s arguments but held that Healy is not entitled to absolute immunity and that Healy forfeited the issue of qualified immunity at this stage. Even considering Healy’s equitable contentions that it would not be “fair” to hold him to today’s standards, the 1975-76 standards of prosecutorial immunity were the same: a prosecutor engaged in certain investigative activities enjoys, not the absolute immunity associated with the judicial process, but only a good-faith defense comparable to the policeman’s.” View "Watkins v. Healy" on Justia Law

The 1936 Randolph-Sheppard Vending Stand Act (RSA), 20 U.S.C. 107(a), authorizes blind persons to operate vending facilities on federal property. The Department of Education prescribes RSA regulations and designates the state agency for issuing RSA licenses. Ohio expands the RSA to state properties. Ohio’s Bureau of Services for the Visually Impaired (BSVI) implements the RSA and Ohio-RSA.Cyrus, a blind vendor, has participated in the Ohio RSA program since 1989. Pursuant to Grantor Agreements with Lucas County and the University of Toledo, Cyrus paid $504,000 in commissions to the university and county. In 2014, the Ohio Attorney General issued a formal opinion that conditioning RSA-vending at state-affiliated universities on commission payments was illegal. Cyrus filed a grievance and stopped making payments to the university. BSVI notified the university that the commission requirement "is void.” BSVI denied Cyrus’s grievance and took no action on the county commissions. A state hearing officer denied relief. Cyrus filed an arbitration complaint under the RSA’.An RSA panel found that BSVI breached its duties by requiring commission payments to both locations The Sixth Circuit held that the RSA prohibits commissions, even for facilities on county-owned properties; prospective relief was appropriate. RSA arbitration panels are enough like civil litigation in Article III courts that sovereign immunity applies. Ohio has not waived its immunity from RSA damages awards imposed by federal arbitration panels. The panel, therefore, exceeded its authority in awarding damages and interest. View "Ohio v. United States Department of Education" on Justia Law

In 2007, Hudson was shot and killed in his Louisville apartment. Detective Roberts sought DNA testing for items at the murder scene. DNA on a hat came back “consistent with a mixture” from Lester, Baker, and an unknown person. Lester and Baker had been implicated by a witness. The case went cold. In 2012, Roberts interviewed Sullivan, an inmate who had contacted the police years before about the murder. Sullivan had dated Hudson and had been friends with Jasmine (the woman living with Baker,). She stated that Jasmine had told her that Baker killed Hudson “over money.” Roberts then interviewed Jasmine, who stated that, on the day of the murder, she, Baker, and “Desean” went to Hudson’s apartment. The men emerged from the apartment with bandanas covering their faces. Baker confessed that he murdered Hudson. Jasmine could not recall “Desean’s” last name and pronounced his first name differently from how Lester pronounces it. She identified Lester’s photo array picture as “Desean.”At trial, Jasmine distanced herself from her identification of Lester. The jury acquitted Lester. Baker was convicted after a second trial. Lester had spent 20 months in jail and three months in home confinement. After his acquittal, he sued Roberts and the Louisville Metro Government.The Sixth Circuit affirmed the summary-judgment rejection of malicious-prosecution claims against Roberts. The Fourth Amendment and Kentucky law required only probable cause for Lester’s pretrial detention and prosecution. Jasmine’s earlier identification of Lester, combined with corroborating evidence like DNA, met that standard. View "Lester v. Roberts" on Justia Law

Hampton pleaded guilty to conspiracy to distribute cocaine and aiding and abetting possession of a firearm in furtherance of the conspiracy. His 204-month sentence was eventually reduced to 180 months based on an amendment to the Sentencing Guidelines. Hampton sought a further reduction by way of compassionate release under 18 U.S.C. 3582(c)(1)(A). Hampton had to exhaust all administrative rights, or, alternatively, wait 30 days after the warden’s first “receipt of [his] request.” Hampton sought administrative relief but filed his motion with the district court before the warden’s 30-day response period had run. The court opted to hold the motion “until the 30-day window ran” and later denied Hampton’s motion “for the reasons stated” in the government’s brief, without further explanation.The Sixth Circuit remanded. Following enactment of the First Step Act, district courts facing defendant-filed motions seeking release under section 3582(c)(1)(A) should analyze whether extraordinary and compelling circumstances merit a sentence reduction and whether the applicable section 3553(a) factors warrant such a reduction. It is not clear whether the court denied Hampton’s motion based upon permissible grounds advanced by the government under section 3582(c)(1)(A)(i)—that Hampton failed to demonstrate extraordinary and compelling circumstances—or instead denied Hampton release due to a strict application of U.S.S.G. 1B1.13, which the government invoked, but which is no longer a mandatory step Hampton must satisfy. View "United States v. Hampton" on Justia Law

An unknown person flagged down Knoxville Officer Whitehead, claiming that Dibrell was selling drugs out of his Chrysler at a Walgreens. Whitehead relayed this tip to three officers who went to the Walgreens and blocked in the Chrysler. An officer patted Dibrell down for weapons and told him to “hang tight.” Officers conversed with Dibrell for about three minutes. Whitehead arrived with his police dog, which alerted to the smell of drugs. The officers searched the Chrysler and found bottles containing hydrocodone, oxycodone, and alprazolam pills. The drugs did not match the bottle labels. Officers searched Dibrell and found more oxycodone pills and $800. A Tennessee state trial court denied his motion to suppress the drugs and money, reasoning that the officers had not detained Dibrell before the dog sniff. An appellate court vacated Dibrell’s convictions, finding that the officers seized Dibrell before the dog sniff and that the anonymous tip did not give them reasonable suspicion to do so.In Dibrell’s suit under 42 U.S.C. 1983, the district court granted the city and the officers summary judgment. The Sixth Circuit affirmed. Although Dibrell was detained (seized) without probable cause or reasonable suspicion to believe that he committed a crime, Dibrell’s challenge to his initial seizure was untimely under rules governing the accrual of a section 1983 claim. His malicious-prosecution claim fails because the state had probable cause to initiate the criminal case once the officers found the drugs. View "Dibrell v. City of Knoxville" on Justia Law

When Anders purchased Star in 2015, Star had been contracted to conduct tows for the Michigan State Police for 15 years and was on the state’s non-preference tow rotation list for Monroe County. The state police’s internal affairs division approached Anders regarding tickets to sporting events that Anders had provided to state troopers. Anders supplied a list of 18 state troopers to whom he had given tickets. Each trooper who accepted tickets was reprimanded. The troopers and others were unhappy that Anders disclosed the names. Cuevas, the commander for the Monroe County Post, informed Anders that he was removing Star from the non-preference tow rotation list. Trooper Hall pressured the Area Towing (Anders's other company) staff to reschedule its auctions. Sollars, the mayor of Taylor, Michigan, required that Area use Fiore, which was under federal investigation, for heavy-duty tows, or lose the contract. Anders was recorded on a federal wiretap speaking to Fiore. Anders revealed to federal agents that he had to work with Fiore to avoid losing the Taylor contract. Sollars vetoed a resolution to allow Area to remain on a month-to-month contract, allegedly because Anders provided information to the FBI. Ramik, a city council member, contacted Fox News, which aired a story in which Ramik accused Anders of stealing from the city.Anders and his companies filed suit under 42 U.S.C. 1983, alleging First Amendment retaliation and Equal Protection violations. The Sixth Circuit reversed the denial of qualified immunity on Area’s claim against Hall. Hall’s alleged “constant pressure” was not an adverse action. The court vacated the denial of qualified immunity on Anders’ Equal Protection claim against Cuevas as insufficiently pleaded but affirmed the denial as to the retaliation claim. The court affirmed the denial of immunity for Sollars and Ramik. View "Anders v. Cuevas" on Justia Law

Kubala worked for Trumbull County as a “fiduciary” employee; he was not under civil-service rules and could participate in partisan political activities. Kubala reported to Smith, who holds an elected position. Kubala claims that Smith sexually harassed him and created a hostile work environment related to Kubala’s supposed homosexuality. Kubala told Laukart, the office manager, about Smith’s comments. Laukart replied that Smith could not be controlled. Kubala claims that Kubala running for political office against Smith’s wife and his attendance at certain political functions triggered an adverse employment action. Smith allegedly told Kubala not to attend certain political functions. Kubala testified that Smith’s attorney asked Kubala if he wanted to change his job status to “classified” because he would be “protected.” Kubala interpreted it as a threat of retaliation because the change would end his involvement in local politics. Kubala’s resignation letter stated he was resigning because the work environment was harming his physical and mental health. Kubala was under the care of a physician and a therapist to cope with the harassment and high blood pressure, which Kubala attributed to his harassment.The Sixth Circuit affirmed the dismissal of Kubala’s 42 U.S.C. 1983 claims. Kubala failed to show that Smith violated his First Amendment rights because the alleged threat is too ambiguous. The district court lacked supplemental jurisdiction over Kubala’s state sexual-harassment claim, which shares no common nucleus of operative fact with his constitutional claim. View "Kubala v. Smith" on Justia Law

Elias pled guilty to drug possession and distribution conspiracy; in 2017, she was sentenced to 108 months' imprisonment. She is confined at FPC Alderson, with a projected release date of November 2024. Elias filed a pro se “Emergency Motion for Immediate Release Due to COVID-19” in April 2020. In June, with appointed counsel, she filed a supplemental motion for a reduction of her sentence under 18 U.S.C. 3582(c)(1)(A)(i), arguing that her hypertension exacerbated her risk of serious injury or death if she were to contract COVID-19. Elias requested that the warden file a compassionate-release motion and appealed the denial, satisfying the exhaustion requirements.The Sixth Circuit affirmed the denial of relief. U.S.S.G. 1B1.13 is not applicable to inmate-filed compassionate release motions under the First Step Act. In determining that there were not “extraordinary and compelling reasons,” the district court properly considered the CDC guidance, which then did not include hypertension; reviewed a scientific journal which stated that “there is as yet no evidence that hypertension is related to outcomes of COVID-19”; examined the BOP’s webpage and noted there were no reported cases at FPC Alderson; and concluded that speculation that COVID-19 could spread to FPC Alderson was insufficient to justify Elias’s release. View "United States v. Elias" on Justia Law

The Health Department issued a resolution closing every school in the county—public, private, and parochial—for grades 7-12, effective December 4, to slow the spread of COVID-19. In the same county, gyms, tanning salons, office buildings, and a large casino remained open. Christian schools filed suit, arguing that the closure of their schools amounts to a prohibition of religious exercise in violation of the First Amendment.The Sixth Circuit, applying strict scrutiny, enjoined enforcement pending appeal, concluding that the closure burdens the plaintiffs' religious practices. The court noted that the schools employed “strict social distancing and hygiene standards” and that “little in-school transmission has been documented.” The court acknowledged that the resolution allowed schools to open for religious education classes or religious ceremonies and that the Department has not targeted the plaintiffs or acted with animus toward religion. The plaintiffs argued that the exercise of their faith is not compartmentalized and pervades each day of in-person schooling so that “a communal in-person environment” is critical to the exercise of their faith. The resolution treats the schools less favorably than it does “comparable secular facilities.” The court rejected an argument that it could consider only the secular actors (other schools) regulated by the resolution. The relevant inquiry is whether the “government, in pursuit of legitimate interests,” has imposed greater burdens on religious conduct than on analogous secular conduct, including gyms, salons, offices, and the Hollywood Casino, which remain open. View "Monclova Christian Academy v. Toledo-Lucas County. Health Department" on Justia Law