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

A commercial fisherman from Erie County, Ohio, who owned a fisheries business, challenged a state rule that amended commercial fishing regulations to exclude seine fishers from receiving yellow perch quotas. The rule, promulgated by the Ohio Department of Natural Resources (ODNR), Division of Wildlife, allocated quotas exclusively to trap net fishers and prohibited the transfer of quotas to seine licenses. The fisherman alleged that this rule deprived him of economic value and constituted a taking without compensation, and further brought claims for breach of fiduciary duty and civil conspiracy against both state and federal defendants.The case was initially heard in the United States District Court for the Northern District of Ohio. The district court dismissed with prejudice all claims against Ohio and the state officials, holding that there was no protected property interest in the value of a fishing license or uncaught fish under the Takings Clause. The court also found that sovereign immunity barred all claims against the state and its officials, even if the claims otherwise had merit, and determined the state law claims were insufficiently pled. Claims against the federal defendants were dismissed without prejudice for defective service of process.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s rulings de novo. The Sixth Circuit affirmed that sovereign immunity barred the takings and state law claims against Ohio and the state officials, rejecting the appellant’s arguments that these defendants had waived immunity or that recent Supreme Court and Ohio Supreme Court decisions required judicial review of the state rule. However, the appellate court held that because the dismissal was based on lack of subject matter jurisdiction, the claims against the state defendants should have been dismissed without prejudice. The court affirmed the dismissal of claims against the federal defendants. The judgment was thus affirmed in part and reversed in part, with instructions to dismiss the state claims without prejudice. View "White's Landing Fisheries, Inc. v. Ohio Dep't of Nat. Res. Div. of Wildlife" on Justia Law

Americare Healthcare Services, Inc., a third-party home care provider in Ohio, and its owner, Dilli Adhikari, hired live-in workers—most of whom cared for their own family members—to provide services to elderly or disabled clients. Between October 2018 and October 2021, Americare failed to pay overtime wages to these employees, claiming entitlement to exemptions under the Fair Labor Standards Act (FLSA): the “Companionship Services Exemption” and the “Live-In Exemption.” The Department of Labor, however, had promulgated a 2013 regulation that prohibited third-party employers from relying on these exemptions.The United States District Court for the Southern District of Ohio granted summary judgment to the Department of Labor, finding Americare and Adhikari liable for willful violations of the FLSA’s overtime requirements. The district court further held that the 2013 Third-Party Regulation was valid, and that Americare and Adhikari lacked standing to challenge a related regulatory definition that narrowed the scope of “companionship services.” Americare and Adhikari appealed only the district court’s rulings on the regulation’s validity and their lack of standing.The United States Court of Appeals for the Sixth Circuit reviewed the case, applying the framework for agency rulemaking authority post-Loper Bright Enterprises v. Raimondo. The Sixth Circuit held that the FLSA’s express statutory delegation allowed the Department of Labor to define and delimit the applicability of the companionship and live-in exemptions, including excluding third-party employers from their reach. The court further held that Americare and Adhikari lacked standing to challenge the definition of companionship services because the bar to their use of the exemption arose from the third-party regulation, not from the definition itself. The judgment of the district court was therefore affirmed. View "Department of Labor v. Americare Healthcare Services" on Justia Law

Four women incarcerated at the Huron Valley Correctional Facility in Michigan suffered from persistent, painful rashes between 2016 and 2019. Despite repeated complaints, medical staff—contracted through Corizon Health—failed to diagnose scabies, instead providing ineffective treatments and attributing the condition to environmental factors like improper laundering. It was only after an outside dermatologist intervened that scabies was correctly identified, prompting prison-wide treatment efforts. However, these efforts were delayed and, in some cases, inadequate, resulting in prolonged suffering for the affected inmates.After their experiences, the four women filed suit in the United States District Court for the Eastern District of Michigan against multiple defendants, including high-level Michigan Department of Corrections officials and Wayne State University medical officers, alleging Eighth Amendment violations and state-law negligence. The district court found that the women’s complaint plausibly alleged “clearly established” Eighth Amendment violations by all defendants and denied the officials’ request for qualified immunity. The court also rejected a claim of state-law immunity, finding that the officials could be the proximate cause of the inmates’ injuries under Michigan law.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denials. The Sixth Circuit held that existing precedent did not “clearly establish” that the non-treating prison officials’ reliance on contracted medical providers was so unreasonable as to violate the Eighth Amendment. Thus, it reversed the district court’s denial of qualified immunity on the federal damages claims. However, the appellate court affirmed the denial of state-law immunity, finding the plaintiffs adequately pleaded proximate cause under Michigan law. The case was remanded for further proceedings consistent with these holdings. View "Machelle Pearson v. MDOC" on Justia Law

This case concerns the approval of Ohio’s Total Maximum Daily Load (TMDL) for phosphorus in the Maumee River watershed, a key regulatory effort to combat harmful algal blooms in Lake Erie. The United States Environmental Protection Agency (U.S. EPA) approved the Ohio Environmental Protection Agency’s (Ohio EPA) TMDL for this region. Plaintiffs, including Lucas County, the City of Toledo, and the Environmental Law & Policy Center, challenged this approval under the Administrative Procedure Act (APA), alleging that it was arbitrary, capricious, and contrary to law.During the litigation in the United States District Court for the Northern District of Ohio, several parties sought to intervene. The court allowed environmental groups and the Ohio EPA to intervene but denied intervention to two sets of proposed defendant-intervenors: various agricultural associations (“Associations”) and the Maumee Coalition II Association (“Coalition”). The district court found that neither the Associations nor the Coalition satisfied the criteria for intervention of right because it presumed the U.S. EPA would adequately represent their interests and that neither group overcame this presumption. The court also denied permissive intervention, concluding that their participation would unnecessarily complicate and delay the proceedings.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denials. The Sixth Circuit affirmed the denial of intervention for the Coalition, finding it had not shown its interests were inadequately represented by existing parties. However, the appellate court reversed the denial for the Associations, holding that they intended to make specific legal arguments distinct from U.S. EPA’s, thereby overcoming the presumption of adequate representation. The court remanded with instructions to allow the Associations to intervene as of right, while affirming the denial of both intervention of right and permissive intervention to the Coalition. View "Lucas Cnty. Bd. of Comm'rs v. Environmental Protection Agency" on Justia Law

Several individuals and organizations challenged a 2018 regulation issued by the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) that classified rifles equipped with bump stocks as illegal machineguns. This rule departed from ATF’s previous position and was prompted by the 2017 Las Vegas shooting, where bump stocks were used to inflict mass casualties. The ATF’s rule gave owners 90 days to destroy or surrender such devices, threatening criminal penalties for noncompliance.In the United States District Court for the Western District of Michigan, the plaintiffs sought to enjoin enforcement of the rule. The district court denied a preliminary injunction, finding the statutory definition of “machinegun” ambiguous and deferring to the ATF’s interpretation under Chevron USA, Inc. v. Natural Resources Defense Council, Inc. On appeal, a Sixth Circuit panel disagreed, finding Chevron inapplicable to statutes with criminal penalties and holding the statutory definition unambiguously excluded bump stocks. However, after en banc review, the Sixth Circuit split evenly, resulting in an affirmation of the district court’s denial. Meanwhile, other circuits reached conflicting outcomes, and the Supreme Court ultimately held in Garland v. Cargill that the statutory definition of “machinegun” does not cover bump stocks.Following the Supreme Court’s decision, the district court declared the ATF’s rule unlawful but denied the plaintiffs’ request for attorney’s fees under the Equal Access to Justice Act, finding the government’s position “substantially justified” due to significant judicial disagreement.The United States Court of Appeals for the Sixth Circuit reviewed this denial and affirmed the district court’s decision. It held that, while the government’s position was ultimately rejected, it was “substantially justified” given the novel statutory question, the division among courts, and the existence of reasonable arguments supporting the ATF’s interpretation. Thus, attorney’s fees were not awarded. View "Gun Owners of America, Inc. v. Bondi" on Justia Law

The plaintiff, a magistrate in the domestic-relations division of a county court, declared her candidacy for a judicial seat alongside a fellow magistrate, who was also a court administrator. During her campaign, the plaintiff distributed literature that criticized her opponent’s work schedule and duties, suggesting that the opponent performed trivial administrative tasks and questioning her competence based on personal circumstances. These campaign materials were perceived by the administrative judge as undermining the integrity of the court and casting both the court and its staff in an unfavorable light. After the plaintiff lost the primary election, the administrative judge terminated her employment as a magistrate.Prior to this appeal, the United States District Court for the Southern District of Ohio dismissed the plaintiff’s suit brought under 42 U.S.C. § 1983, which alleged a violation of her First Amendment free-speech rights. The district court ruled that the court itself was not a legally cognizable entity subject to suit, that sovereign immunity barred claims for money damages against the administrative judge in her official capacity, and that the plaintiff failed to state a plausible free-speech claim against the administrative judge. The plaintiff appealed only the dismissal of her free-speech claim.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. It held that, because the plaintiff occupied a confidential or policymaking position and her campaign speech addressed matters related to court policy and politics in a manner that undermined the loyalty and efficient functioning required by her employer, her termination did not violate the First Amendment. The court affirmed the district court’s judgment, finding that the balancing test usually applied to public employee speech was unnecessary under these circumstances. The court also rejected the plaintiff’s arguments regarding insubordination, the scope of judicial candidate speech protections, and the applicability of strict scrutiny. View "Gaines v. Cross" on Justia Law

This case concerns a challenge to new regulations issued by the Centers for Disease Control and Prevention (CDC) regarding the importation of dogs into the United States. The CDC, responding to incidents in which rabid dogs entered the country using fraudulent paperwork, amended its regulations to require that all imported dogs have a microchip, be at least six months old, and that importers submit a Dog Importation Form. These measures were intended to ensure the identity of the dogs, their vaccination status, and prevent the introduction of rabies, which remains a risk in other countries.Plaintiffs, consisting of a U.S. hunter, a Canadian dog breeder, and a hunting organization, filed suit in the United States District Court for the Western District of Michigan. They argued that the age and microchip requirements exceeded the CDC's statutory authority and were arbitrary and capricious. They sought a preliminary injunction to prevent enforcement of these requirements, particularly as applied to dogs from rabies-free and low-risk countries. The magistrate judge recommended, and the district court agreed, that the plaintiffs failed to show a likelihood of success on the merits, and denied the injunction. Plaintiffs then appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of the preliminary injunction. The appellate court concluded that the plaintiffs were unlikely to succeed on the merits of their claims. The court held that the age and microchip requirements were likely within the CDC’s statutory authority under 42 U.S.C. § 264, as they constitute inspections or other necessary measures to prevent the introduction of communicable diseases. The court also determined that the rulemaking was not arbitrary or capricious. Accordingly, the Sixth Circuit affirmed the district court’s denial of the preliminary injunction. View "U.S. Sportsmen's Alliance Found. v. Centers for Disease Control and Prevention" on Justia Law

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