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

In March 2020, Andrew Cooperrider, owner of Brewed, a coffee shop and bar in Lexington, Kentucky, criticized Governor Beshear’s COVID-19 policies on social media. In November 2020, the Kentucky Department of Alcoholic Beverage Control (DABC) suspended Brewed’s alcohol license, and officially revoked it in March 2022. Cooperrider filed a lawsuit against Governor Beshear, DABC officials, and other state officials, alleging First Amendment retaliation and due-process violations, claiming the license revocation was in retaliation for his critical speech.The United States District Court for the Eastern District of Kentucky dismissed the case, granting the defendants' motions to dismiss. The court found that most of Cooperrider’s claims were barred by absolute, qualified, and sovereign immunity. It also determined that Cooperrider’s remaining substantive-due-process claim did not meet the Rule 12(b)(6) pleading standard.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s dismissal of most claims, agreeing that the defendants were protected by absolute, qualified, and sovereign immunity. However, the appellate court found that the district court improperly granted qualified immunity to Governor Beshear, Ray Perry, and Wesley Duke regarding Cooperrider’s First Amendment retaliation claim. The appellate court held that Cooperrider had plausibly alleged that the enforcement action against Brewed was motivated by his protected speech. Consequently, the court reversed the district court’s decision on this point and remanded the case for further proceedings on the First Amendment retaliation claim. View "Cooperrider v. Woods" on Justia Law

Louis Chandler, a Michigan prisoner, was convicted of two counts of first-degree criminal sexual conduct and sentenced to concurrent terms of twenty-five to seventy-five years in prison. Chandler filed a habeas corpus petition, claiming that the trial court infringed his right to present a complete defense. The district court denied the petition, and Chandler appealed.The United States District Court for the Western District of Michigan initially reviewed the case and denied Chandler's habeas corpus petition. Chandler argued that the trial court's refusal to delay the trial, exclusion of key witnesses, and prevention of presenting critical evidence violated his constitutional rights. The Michigan Court of Appeals found that the trial court had abused its discretion by denying Chandler's requests for an adjournment, barring his witnesses, and excluding evidence of the victim's prior false allegations. However, the appellate court affirmed Chandler's conviction, concluding that the errors were not outcome determinative under the state's non-constitutional error standard.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the trial court's actions significantly undermined Chandler's ability to present a complete defense. The court held that the exclusion of evidence and witnesses critical to Chandler's defense violated his constitutional rights. The court concluded that the errors had a substantial and injurious effect on the jury's verdict, creating grave doubt about the trial's fairness.The Sixth Circuit reversed the district court's decision, conditionally granted Chandler's habeas corpus petition, and remanded the case with instructions to order Chandler's release unless the State of Michigan grants him a new trial within ninety days. View "Chandler v. Brown" on Justia Law

The case involves Michigan's electricity market regulations, specifically the Individual Local Clearing Requirement (ILCR), which mandates that electricity retailers in Michigan's lower peninsula procure a certain percentage of their capacity from within that region. Plaintiffs, including Energy Michigan and the Association of Businesses Advocating Tariff Equity (ABATE), challenged the ILCR on the grounds that it violates the dormant Commerce Clause by discriminating against interstate commerce.The United States District Court for the Eastern District of Michigan initially dismissed the Michigan Public Service Commission (MPSC) on Eleventh Amendment grounds but allowed the case to proceed against individual commissioners. The court denied summary judgment motions from both sides, finding that there were factual disputes regarding whether the ILCR discriminated against interstate commerce. After a three-day bench trial, the district court concluded that the ILCR did not violate the Commerce Clause.The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the ILCR is facially discriminatory because it requires electricity to be generated within a specific geographic region, effectively favoring in-state over out-of-state electricity. The court held that this discrimination necessitates strict scrutiny, which the district court did not properly apply. The Sixth Circuit reversed the district court's judgment and remanded the case for further proceedings to determine if the ILCR can survive strict scrutiny by proving it is the only means to achieve the state's goal of ensuring a reliable energy supply. View "Energy Michigan, Inc. v. Public Service Commission" on Justia Law

Zillow, Inc., a for-profit corporation, requested property tax data from several Kentucky property valuation administrators (PVAs) under Kentucky’s Open Records Act (KORA). The PVAs classified Zillow’s requests as having a commercial purpose and quoted fees amounting to thousands of dollars. Zillow sued, arguing that KORA’s fee structure, which distinguishes between commercial and non-commercial purposes and includes exceptions for newspapers, radio, and television stations, violated the First and Fourteenth Amendments.The United States District Court for the Eastern District of Kentucky held that the commercial/non-commercial distinction did not violate the First or Fourteenth Amendments but found the newspaper exception unconstitutional. The court severed the newspaper exception from the statute, resulting in both Zillow and newspapers being subject to enhanced fees. The Kentucky Press Association and American City Business Journals intervened and, along with Zillow, appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the commercial-fee statute did not violate the First Amendment as applied to Zillow. It determined that the distinction between commercial and non-commercial purposes was content-neutral and did not impermissibly discriminate based on the content of Zillow’s speech. The court reversed the district court’s order declaring the newspaper exception unconstitutional, vacated the permanent injunction, and remanded with instructions to grant summary judgment to the PVAs. View "Zillow, Inc. v. Miller" on Justia Law

In Michigan, citizens can amend the state constitution through ballot initiatives without legislative approval. Two state senators and nine state representatives challenged the use of such initiatives to regulate federal elections, arguing it violated the U.S. Constitution's Elections Clause. They sought to prevent Michigan officials from enforcing these amendments.The United States District Court for the Western District of Michigan dismissed the case, ruling that the legislators lacked standing to sue under Civil Rule 12(b)(1). The court found that the plaintiffs did not demonstrate a concrete injury necessary for standing.The United States Court of Appeals for the Sixth Circuit affirmed the district court's dismissal. The appellate court held that the legislators did not have standing because they did not represent the entire legislature or a controlling bloc within it. The court distinguished this case from precedents where entire legislatures or controlling blocs had standing to sue. The court emphasized that individual legislators generally lack standing to assert institutional injuries of the legislature. The court also noted that the legislators had not shown that their votes were nullified by the amendments, as required for standing under relevant Supreme Court precedents.The Sixth Circuit concluded that the legislators' claims did not meet the requirements for standing under Article III of the U.S. Constitution, as they did not suffer a concrete and particularized injury. The court affirmed the district court's dismissal of the case. View "Lindsey v. Whitmer" on Justia Law

Jaylin Morton was indicted for possessing a firearm as a felon, in violation of 18 U.S.C. § 922(g)(1). Morton moved to dismiss the indictment, arguing that the prosecution violated his Second Amendment rights. The district court denied his motion, and Morton conditionally pleaded guilty, retaining the right to appeal the denial of his motion to dismiss.The United States District Court for the Eastern District of Kentucky denied Morton’s motion to dismiss, reasoning that his prior felonies demonstrated that he was a serious and direct threat to public safety. The court concluded that § 922(g)(1) constitutionally applied to him. Morton then appealed the district court’s decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Morton’s criminal history, which included multiple violent offenses such as shooting at his ex-girlfriend and her family, and assaulting his then-girlfriend, demonstrated his dangerousness. The court applied the framework established in United States v. Williams, which allows for disarming individuals who are deemed dangerous based on their criminal history. The court concluded that Morton’s conviction was consistent with the Second Amendment as interpreted in Williams and affirmed the district court’s denial of Morton’s motion to dismiss the indictment. View "United States v. Morton" on Justia Law

Randell Shepherd, a career coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA), invoking the Act’s presumption that he was entitled to benefits due to his over fifteen years of mining and total disability from chronic obstructive pulmonary disease (COPD), bronchitis, and emphysema. Incoal, Inc., Shepherd’s most recent employer, contested his entitlement, arguing that his disability was caused by smoking, not mining. An administrative law judge (ALJ) found Incoal’s expert opinions unpersuasive and inconsistent with the Act’s regulations and preamble, which recognize pneumoconiosis as a latent and progressive disease. The ALJ ruled that Incoal failed to rebut the presumption that Shepherd was entitled to benefits. The Benefits Review Board (BRB) affirmed the ALJ’s decision.Incoal petitioned the United States Court of Appeals for the Sixth Circuit for review, arguing that the ALJ improperly relied on the regulatory preamble over their evidence and that the presumption was effectively irrebuttable, violating the Constitution and the Administrative Procedure Act (APA). The court reviewed the case de novo, focusing on whether the ALJ’s decision was supported by substantial evidence and correctly applied the law.The Sixth Circuit held that the ALJ was entitled to reference the preamble to assess the credibility of expert opinions and found that the ALJ’s decision was supported by substantial evidence. The court noted that the BLBA’s rebuttable presumption is constitutional, as it is based on a rational relationship between the length of a miner’s career and the risk of pneumoconiosis. The court concluded that Incoal’s arguments were unpersuasive and that the ALJ applied the correct legal principles. Consequently, the court denied Incoal’s petition for review. View "Incoal, Inc. v. OWCP" on Justia Law

In 2005, Delano Hale was sentenced to death by an Ohio court for the murder of Douglas Green. Green was found dead in a motel room, wrapped in plastic bags, and had been shot multiple times. Hale was arrested driving Green's stolen vehicle and later admitted to the shooting, claiming it was in self-defense against Green's sexual advances. Hale was convicted of aggravated murder and other charges, and the jury recommended the death penalty.Hale's conviction and sentence were affirmed by the Ohio Supreme Court and the Ohio Court of Appeals. Hale filed for post-conviction relief, which was denied by the trial court and affirmed by the appellate court. He then sought federal habeas relief, raising multiple claims, including ineffective assistance of counsel and sentencing errors under Blakely v. Washington.The United States Court of Appeals for the Sixth Circuit reviewed Hale's habeas petition. The court denied Hale's claim of ineffective assistance of counsel, finding that his trial counsel's decision not to call a forensic expert was a reasonable strategic choice. The court noted that Hale's counsel had considered hiring an expert but ultimately chose a different strategy, which did not constitute deficient performance under Strickland v. Washington.The court also denied Hale's claim regarding his noncapital sentences, which were enhanced based on judicial factfinding in violation of Blakely. The Ohio Supreme Court had reviewed this claim for plain error and found no prejudice, concluding that a jury would have reached the same sentencing conclusions. The Sixth Circuit found this determination reasonable and upheld the Ohio Supreme Court's decision.The Sixth Circuit affirmed the district court's denial of Hale's habeas petition, concluding that Hale's claims did not warrant relief under the deferential standards of the Antiterrorism and Effective Death Penalty Act (AEDPA). View "Hale v. Cool" on Justia Law

The plaintiffs, Glenn Bowles, Kenneth Franks, and Robert Gardner, challenged the constitutionality of Michigan's Court of Claims Act. Bowles and Franks, former police academy instructors, faced employment actions after allegations of misconduct, while Gardner, a former doctoral student, faced expulsion and subsequent employment issues due to his advocacy for migrant workers. They argued that the Act violated their Fourteenth Amendment rights by requiring Court of Appeals judges to serve on the Court of Claims, thus creating potential bias in appellate reviews and denying them jury trials.The United States District Court for the Eastern District of Michigan dismissed their complaint. The court found that the plaintiffs lacked standing as they did not demonstrate how the Court of Claims Act directly caused their injuries. Additionally, the court held that Bowles's claims were precluded due to a prior federal lawsuit and concluded that the plaintiffs' constitutional claims lacked merit.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit agreed that the plaintiffs lacked Article III standing. The court noted that the plaintiffs' injuries were not fairly traceable to the actions of Michigan's Governor and Attorney General, who were named as defendants. The court also found that the requested relief, an injunction against the enforcement of the Court of Claims Act, would not redress the plaintiffs' employment-related injuries. Consequently, the Sixth Circuit affirmed the district court's dismissal of the case on jurisdictional grounds, modifying the judgment to a dismissal without prejudice. View "Bowles v. Whitmer" on Justia Law

In May 2023, Martavious Kincaide pleaded guilty to three federal firearms offenses in the Western District of Kentucky. Deandre Swain, a criminal defendant in Kentucky state court, sought to intervene in Kincaide’s case to unseal a document titled “Plea Agreement Supplement.” Swain believed this document might contain a cooperation agreement that could aid his defense in his state court case. The Western District of Kentucky requires that all plea supplements, which may contain cooperation agreements, be sealed to protect cooperators from potential harm.The United States District Court for the Western District of Kentucky denied Swain’s motion to intervene. The court held that the General Order 2010-06, which mandates the sealing of plea supplements, was consistent with the First Amendment. The court reasoned that the order was the narrowest method to protect the safety of cooperators and that Swain’s specific interest did not override the need for consistency in applying the General Order.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The Sixth Circuit held that there is no qualified First Amendment right of access to cooperation agreements. The court applied the “experience and logic” test from Press-Enterprise Co. v. Superior Court, concluding that there is no historical tradition of public access to such documents and that public access would not play a significant positive role in the functioning of the judicial process. The court emphasized that public access to cooperation agreements could endanger cooperators and undermine government investigations. Thus, the denial of Swain’s motion to intervene was affirmed. View "United States v. Kincaide" on Justia Law