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

HRT Enterprises owned an 11.8-acre parcel adjacent to Detroit’s Coleman A. Young International Airport, with about 20 percent of the property falling within a regulated runway “visibility zone” that restricted development. Over time, the City of Detroit acquired other properties in a nearby area for airport compliance but did not purchase HRT’s. By late 2008, HRT’s property had become vacant and vandalized, and HRT alleged it could no longer use, lease, or sell the property due to City actions and regulatory restrictions.HRT first sued the City in Michigan state court in 2002, alleging inverse condemnation, but the jury found for the City; the Michigan Court of Appeals affirmed, and the Michigan Supreme Court denied leave to appeal. In 2008, HRT sued in federal court, but the United States District Court for the Eastern District of Michigan dismissed the action without prejudice because HRT had not exhausted state remedies. HRT then filed a second state suit in 2009, which was dismissed on res judicata grounds; the Michigan Court of Appeals affirmed. HRT did not seek further review.In 2012, HRT filed the present action in federal court, alleging a de facto taking under 42 U.S.C. § 1983. The district court denied the City’s preclusion arguments, granted summary judgment to HRT on liability, and held that a taking had occurred, leaving the date for the jury. A first jury found the taking occurred in 2009 and awarded $4.25 million; the court ordered remittitur to $2 million, then a second jury, after a new trial, awarded $1.97 million.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings, holding that HRT’s claim was ripe, not barred by claim or issue preclusion, that the district court properly granted summary judgment on liability, and that its remittitur decision was not an abuse of discretion. View "HRT Enterprises v. City of Detroit" on Justia Law

A research scientist who had worked for over a decade at a public university in Ohio coauthored several well-regarded articles during her tenure. After she left the university for a new position, allegations of research misconduct surfaced regarding some of her publications. The university convened an investigative committee, as required by federal regulations due to its receipt of federal funding. The committee found that she had committed research misconduct and recommended barring her from future university employment, retracting or correcting certain articles, and reported its findings to relevant journals and her current employer. The scientist alleged that the committee deviated from standard investigatory procedures, failed to provide exculpatory evidence, and did not require proof of intent or recklessness.The United States District Court for the Southern District of Ohio dismissed her complaint, which had sought equitable relief under federal and state law. The court held that sovereign immunity shielded the university’s Board of Trustees and the officials sued in their official capacities from most claims. It found several claims time-barred and determined that the remaining constitutional claims, including due process and equal protection, failed on the merits. The court declined to exercise supplemental jurisdiction over the state-law claims against individuals in their personal capacities.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The court held that sovereign immunity barred all claims against the Board of Trustees and all state-law claims against the officials in their official capacities. As to the remaining federal due process claims, the court determined that the plaintiff failed to identify a constitutionally protected liberty interest under the stigma-plus doctrine and that the alleged conduct—even if malicious or in violation of confidentiality regulations—did not amount to conscience-shocking behavior under substantive due process standards. View "Pichiorri v. Burghes" on Justia Law

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 case concerns two decisions made by the Environmental Protection Agency (EPA) regarding air quality standards in the Detroit area under the Clean Air Act (CAA). Michigan sought to redesignate the Detroit area from nonattainment to attainment for the 2015 ozone National Ambient Air Quality Standards (NAAQS), relying on air quality data from 2019–2021. However, in June 2022, the area recorded exceedances attributed to wildfire smoke from Canada. Michigan requested the EPA to exclude these exceptional-event data points. Meanwhile, Detroit missed its attainment deadline and was reclassified from Marginal to Moderate nonattainment, triggering additional requirements for Reasonably Available Control Technology (RACT) implementation.After Detroit missed its attainment deadline, the EPA finalized its determination of nonattainment and reclassified the area as Moderate nonattainment, setting deadlines for Michigan to submit RACT revisions. Michigan submitted its redesignation request before these RACT requirements became effective. The EPA later approved Michigan’s exceptional-events request and redesignated Detroit to attainment, despite Michigan not having implemented the newly required RACT measures for Moderate nonattainment areas. Sierra Club challenged both the EPA’s approval of the exceptional-event exclusion and the subsequent redesignation.The United States Court of Appeals for the Sixth Circuit reviewed both EPA actions. The court held that the EPA’s approval of Michigan’s exceptional-event request was not arbitrary or capricious, finding that the agency had adequately explained its reasoning and considered the relevant data linking wildfire smoke to the ozone exceedances. However, the court vacated the EPA’s redesignation of Detroit to attainment, holding that the CAA requires a state to satisfy all requirements applicable at the time of redesignation, not merely those in effect when the redesignation request was submitted. Because Michigan had not met the RACT requirements by the time of redesignation, the EPA’s action was contrary to law. Thus, the approval of the exceptional-event request was affirmed, and the redesignation was vacated. View "Sierra Club v. Environmental Protection Agency" 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

A resident of University Heights, Ohio, who practices Orthodox Judaism, sought to use his home for group prayer sessions due to religious obligations and restrictions on travel during the Sabbath. After inviting neighbors to participate in these gatherings, a neighbor complained to city officials, prompting the city’s law director to send a cease-and-desist letter, warning that using the home as a place of religious assembly violated local zoning laws. The resident then applied for a special use permit to operate a house of worship but withdrew his application before the city’s Planning Commission could reach a decision, stating he did not wish to operate a house of worship as defined by the ordinance. Despite withdrawing, he later filed a federal lawsuit against the city and several officials, alleging violations of federal and state law, including constitutional and statutory claims.The United States District Court for the Northern District of Ohio granted summary judgment for the city and its officials. The court found that the plaintiff’s claims under the Religious Land Use and Institutionalized Persons Act (RLUIPA), the First and Fourteenth Amendments, and the Ohio Constitution were unripe because there was no final decision by the relevant local authorities regarding the application of the zoning ordinance to his property. The court also rejected his Fourth Amendment and Freedom of Access to Clinic Entrances Act (FACE Act) claims on the merits and declined supplemental jurisdiction over a state public records claim.The United States Court of Appeals for the Sixth Circuit affirmed. The court held that most of the plaintiff’s claims were unripe because he withdrew his application before any final decision was made by the city’s zoning authorities, and thus there was no concrete dispute for federal review. The court also held that his facial challenges to the ordinance were forfeited and, in any event, failed as a matter of law. The court further concluded that the Fourth Amendment and FACE Act claims failed on the merits and found no abuse of discretion in declining supplemental jurisdiction over the state law claim. View "Daniel Grand v. City of University Heights, Ohio" on Justia Law

A shift supervisor at a coffee shop in Ann Arbor, Michigan, led efforts to organize a union at her workplace. She was a prominent organizer, engaging in various activities such as wearing union buttons, speaking to customers about unionization, and attending a labor board hearing. Several months into the campaign, she was terminated by her employer, who cited her violation of a company policy requiring at least two employees to be present in the café. The supervisor had left a barista alone at the store at the end of her shift without notifying management, which the company claimed was the reason for her discharge.After her termination, Workers United filed unfair labor practice charges with the National Labor Relations Board (NLRB), alleging that the discharge was motivated by anti-union animus. An Administrative Law Judge found in favor of the union, concluding that the employer’s stated reason was pretextual and that the discharge was unlawfully motivated. The NLRB affirmed the ALJ’s decision and expanded the remedy, ordering the employer to compensate the supervisor not only for lost earnings and benefits but also for any “direct or foreseeable pecuniary harms” resulting from the discrimination.The United States Court of Appeals for the Sixth Circuit reviewed the case on the NLRB’s application for enforcement of its order. The court held that substantial evidence supported the NLRB’s finding that the supervisor’s discharge was motivated by anti-union animus and thus constituted an unfair labor practice. However, the court determined that the NLRB exceeded its statutory authority under the National Labor Relations Act by awarding compensation for “direct or foreseeable pecuniary harms” beyond lost earnings and benefits. The court granted enforcement of the unfair labor practice finding but vacated the expanded remedy and remanded for further proceedings. View "National Labor Relations Board v. Starbucks Corp." on Justia Law

Donald Roberts and Gun Owners of America challenged the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) after the agency issued a 2020 advisory instructing gun sellers not to accept Michigan concealed-pistol licenses as substitutes for the federally required National Instant Criminal Background Check System (NICS) check. Roberts was denied a gun purchase when he presented his Michigan license, prompting the lawsuit. The plaintiffs sought an injunction against enforcement of the advisory and a declaration that the ATF had exceeded its authority under the Administrative Procedure Act.The United States District Court for the Eastern District of Michigan initially granted summary judgment to the ATF on the merits. On appeal, the United States Court of Appeals for the Sixth Circuit vacated that order and remanded for further consideration of state law requirements. On remand, the district court dismissed the complaint for lack of standing, leading to another appeal.After the district court’s dismissal, the ATF issued a new advisory in May 2025, following a presidential executive order, which recognized Michigan licenses as valid alternatives to NICS checks and superseded the 2020 advisory. The United States Court of Appeals for the Sixth Circuit determined that these developments rendered the case moot, as the challenged policy was no longer in effect and the plaintiffs sought only prospective relief. The court found that neither the voluntary cessation nor the capable-of-repetition exceptions to mootness applied. Accordingly, the Sixth Circuit vacated the district court’s dismissal for lack of standing and remanded with instructions to dismiss the case as moot. View "Gun Owners of America, Inc. v. Dep't of Justice" on Justia Law