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

A train operated by Norfolk Southern carrying hazardous materials derailed near East Palestine, Ohio, in February 2023. The cleanup released toxic chemicals into the surrounding area, prompting affected residents and businesses to file suit against the railroad and other parties in federal court. These cases were consolidated into a master class action, and after extensive discovery and mediation, Norfolk Southern agreed to a $600 million settlement for the class. The district court for the Northern District of Ohio approved the settlement in September 2024. Five class members objected and appealed, but the district court required them to post an $850,000 appeal bond by January 30, 2025, to cover administrative and taxable costs. The objectors did not pay the bond or offer a lesser amount.After the bond order, the objectors filed a motion in the United States Court of Appeals for the Sixth Circuit to eliminate or reduce the bond, but did not seek a stay. The Sixth Circuit motions panel explained that, absent a separate notice of appeal, it could only address the bond on a motion to stay, which the objectors expressly disclaimed. The objectors then moved in the district court to extend the time to appeal the bond order, but did so one day after the deadline set by Federal Rule of Appellate Procedure 4(a)(5)(A). The district court denied the motion as untimely, finding it lacked jurisdiction to grant an extension.The United States Court of Appeals for the Sixth Circuit held that the deadlines for appealing and requesting extensions are jurisdictional and cannot be equitably extended. The court dismissed the objectors’ appeal of the motion to extend for lack of jurisdiction and granted the plaintiffs’ motion to dismiss the objectors’ appeals of the settlement for failure to pay the required bond. View "In re E. Palestine Train Derailment" on Justia Law

Kia and Hyundai manufactured millions of vehicles between 2011 and 2021 that lacked engine immobilizers, a standard anti-theft device, and had ignition assemblies that were easily compromised. These design features made the cars especially vulnerable to theft, leading to a surge in thefts nationwide, particularly after a viral social media trend demonstrated how to steal these vehicles. In two separate incidents, teenagers stole such cars and, while driving them, caused accidents that resulted in severe injury to Donald Strench and the death of Matthew Moshi. Strench and Moshi’s estate brought suit against Hyundai and Kia, respectively, alleging that the companies were liable under the Ohio Product Liability Act (OPLA) for design defects that made the cars susceptible to theft and, consequently, to the resulting injuries.The United States District Court for the Southern District of Ohio dismissed the claims, holding that the plaintiffs could not establish proximate causation as a matter of Ohio law. The district court relied on Ohio precedents that generally absolve car owners of liability for injuries caused by thieves who steal their cars, applying the same reasoning to the manufacturers.On appeal, the United States Court of Appeals for the Sixth Circuit held that the Ohio cases concerning car owners’ liability do not control product liability claims against manufacturers. The Sixth Circuit found that, under OPLA and Ohio common law, foreseeability must be assessed from the perspective of a manufacturer, who is expected to have specialized knowledge of risks, including those arising from third-party theft. The court concluded that the plaintiffs plausibly alleged that the manufacturers should have foreseen the risk of theft-related accidents. The Sixth Circuit reversed the district court’s dismissal of the design defect and inadequate warning claims, but affirmed the dismissal of the manufacturing defect and nonconformance to representation claims. The case was remanded for further proceedings on the surviving claims. View "Moshi v. Kia Motors Am., Inc." on Justia Law

A woman experiencing a mental health crisis called 911 and requested that police come to her home to shoot her. Three officers responded and found her holding a bat and a pickaxe. The officers maintained a distance of about fifteen feet and attempted to de-escalate the situation, with one officer assuring her that she would not be harmed. After several minutes, and following an interaction with the woman’s mother, one officer tased her, and another officer shot her multiple times as she moved in the direction of the officers. The woman survived but suffered severe injuries.The plaintiff, acting on the woman’s behalf, filed suit in the United States District Court for the Middle District of Tennessee against the two officers and the Metropolitan Government of Nashville and Davidson County under 42 U.S.C. § 1983, alleging excessive force in violation of the Fourth Amendment, and also brought a negligence claim against the municipality. The officers moved to dismiss the complaint on qualified immunity grounds, and the municipality sought judgment on the pleadings. The district court granted the officers’ motion to dismiss the excessive force claims and the municipality’s motion on the negligence claim, but initially denied the municipality’s motion as to the § 1983 claim. Later, the district court granted the municipality’s motion for judgment on the pleadings on the § 1983 claim as well.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the complaint plausibly alleged that both officers violated the woman’s clearly established Fourth Amendment rights by tasing and shooting her under the circumstances described. The court also held that the district court erred in dismissing the municipal liability claim. Accordingly, the Sixth Circuit reversed the dismissal of the claims against the officers, vacated the judgment for the municipality, and remanded for further proceedings. View "Chrestman v. Metropolitan Government of Nashville and Davidson County" on Justia Law

Samantha Graf worked as a Certified Nursing Assistant Technician at Morristown-Hamblen Hospital Association (MHHA). She alleged that during a lunch break on hospital grounds, a security guard employed by a third-party firm raped her. Graf reported the incident to hospital human resources, but after a limited investigation, HR concluded the sexual encounter was consensual. MHHA terminated Graf for violating hospital policy by having intercourse while on the clock and in an unauthorized area. Graf continued to communicate with the security guard after the incident, and both parties disputed the nature of their relationship and the encounter.Graf filed suit in the United States District Court for the Eastern District of Tennessee, asserting claims under Title VII and the Tennessee Human Rights Act (THRA), as well as state tort claims. The district court dismissed several claims and one defendant, Shield and Buckler Security, Inc., on statute of limitations grounds. After summary judgment, only Graf’s retaliation claims under Title VII and THRA, and her negligent infliction of emotional distress claim, proceeded to trial. Before trial, the district court ruled on the admissibility of evidence regarding Graf’s sexual history, allowing some communications with the security guard but excluding other evidence under Federal Rule of Evidence 412. The jury found in favor of MHHA on all counts, and judgment was entered against Graf.On appeal to the United States Court of Appeals for the Sixth Circuit, Graf argued that the district court erred in requiring her to prove she did not consent to the alleged rape for her Title VII retaliation claim, and in admitting evidence of her sexual history. The Sixth Circuit held that a Title VII retaliation plaintiff must demonstrate a reasonable and good-faith belief that the conduct opposed was unlawful, and that evidence regarding consent was relevant to this inquiry. The court also found no abuse of discretion in the district court’s evidentiary rulings. The judgment was affirmed. View "Graf v. Morristown-Hamblen Hospital" on Justia Law

Two students at a private college in Michigan alleged that they were sexually assaulted by fellow students—one incident occurring in an on-campus dormitory and the other in an off-campus apartment. Both students reported the assaults to college officials, who initiated investigations led by outside lawyers. The students claimed that the college’s response was inadequate: one student’s assailant received no additional punishment due to a prior infraction, and the other’s assailant was disciplined but later allowed to rejoin the baseball team. Both students experienced emotional distress and academic or personal setbacks following the incidents.The students filed suit in the United States District Court for the Western District of Michigan, asserting state-law claims for negligence, intentional infliction of emotional distress, and sex discrimination under Michigan’s civil rights statute, on behalf of themselves and a proposed class. The district court granted the college’s motion to dismiss for failure to state a claim, finding that the plaintiffs had not alleged sufficient facts to support any of their claims.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that Michigan law does not impose a general duty on colleges to protect students from criminal acts by third parties, absent a special relationship or foreseeability of imminent harm to identifiable individuals, neither of which was present here. The court also found that the alleged conduct by the college did not rise to the level of “extreme and outrageous” required for an intentional infliction of emotional distress claim. Finally, the court concluded that the plaintiffs failed to allege facts showing either disparate treatment or disparate impact based on sex under Michigan’s civil rights law. Accordingly, the Sixth Circuit affirmed the district court’s dismissal of all claims. View "Chen v. Hillsdale College" on Justia Law

Several individuals from five different states purchased ovens with front-mounted burner knobs manufactured by a major appliance company. They allege that these ovens have a defect causing the stovetop burners to turn on unintentionally, sometimes resulting in gas leaks. The plaintiffs claim they were unaware of this defect at the time of purchase, but that the manufacturer had prior knowledge of the issue through consumer complaints sent to the U.S. Consumer Product Safety Commission (CPSC) and reviews posted on the company’s website. The plaintiffs assert that, had they known about the defect, they would have paid less for the ovens or not purchased them at all.The plaintiffs filed a class action in the United States District Court for the Western District of Michigan, alleging violations of federal warranty law, fraud by omission, breach of express and implied warranties, unjust enrichment, and violations of state consumer protection statutes. The district court found that the plaintiffs had Article III standing, as they alleged a concrete injury, but dismissed all claims for failure to state a plausible claim for relief. The plaintiffs appealed the dismissal of their state common law fraud and statutory consumer protection claims, while the manufacturer argued that the plaintiffs lacked standing.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the plaintiffs had Article III standing because they plausibly alleged economic injury from overpaying for a defective product. The court further held that the plaintiffs plausibly alleged the manufacturer’s knowledge of the defect and its safety risks, particularly because the CPSC had sent incident reports directly to the manufacturer. The court reversed the district court’s dismissal of most state law fraud and consumer protection claims, except for the Illinois common law fraud claim, which failed for lack of a duty to disclose under Illinois law. The case was remanded for further proceedings consistent with these holdings. View "Tapply v. Whirlpool Corp." on Justia Law

Plaintiffs in this multi-district products liability suit allege that they purchased defective Chrysler Pacifica minivans from FCA, which were recalled due to a risk of battery explosions. After the recall, plaintiffs filed seven putative class action suits, which were consolidated in the Eastern District of Michigan. During discovery, FCA discovered that some plaintiffs had agreed to arbitration clauses when purchasing their minivans and moved to compel arbitration for those plaintiffs. The district court denied FCA’s motion, finding that FCA had waived its right to arbitrate by moving to dismiss the entire complaint.The United States District Court for the Eastern District of Michigan denied FCA’s motion to compel arbitration, concluding that FCA had waived its right to arbitrate by engaging in litigation conduct inconsistent with that right, specifically by moving to dismiss the plaintiffs’ claims. The district court made this finding sua sponte, without the plaintiffs raising the issue of waiver.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 a party cannot waive its right to arbitration without knowledge of that right. The court found that FCA did not know about the arbitration clauses until it obtained the relevant purchase agreements through discovery. Additionally, the appellate court determined that the district court erred by raising the issue of waiver on its own, violating the principle of party presentation. The Sixth Circuit concluded that the district court’s decision was clearly erroneous and remanded the case for further proceedings consistent with its opinion. View "Berzanskis v. FCA US, LLC" on Justia Law

Robert Cox, acting as the personal representative and special administrator of the estate of Greta Cox, sued Total Quality Logistics, Inc. and Total Quality Logistics, LLC (collectively, TQL) for negligence under Ohio law. Cox alleged that TQL, in its role as a freight broker, negligently hired an unsafe motor carrier, Golden Transit, Inc., which resulted in a motor vehicle crash that killed his wife, Greta Cox. The crash occurred when the driver of the motor carrier, Amarjit Singh Khaira, failed to slow down in a construction zone and collided with Greta Cox's vehicle.The United States District Court for the Southern District of Ohio dismissed the case, ruling that Cox’s claims were preempted by the Federal Aviation Administration Authorization Act (FAAAA), specifically 49 U.S.C. § 14501(c). The district court found that the FAAAA preempted the state law claims because they related to the services of a broker with respect to the transportation of property and did not fall within the Act’s safety exception.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred in its interpretation of the FAAAA’s safety exception. The Sixth Circuit concluded that the safety exception, which preserves the safety regulatory authority of a state with respect to motor vehicles, includes common law claims like Cox’s negligent hiring claim. The court reasoned that such claims are genuinely responsive to safety concerns and directly involve motor vehicles and motor vehicle safety. Therefore, the court reversed the district court’s judgment and remanded the case for further proceedings consistent with its opinion. View "Cox v. Total Quality Logistics, Inc." on Justia Law

Randy Wiertella died in the Lake County Adult Detention Facility on December 10, 2018. Dennis Wiertella, as the Administrator of Randy's estate, filed a lawsuit claiming that Randy's constitutional rights under the Eighth and Fourteenth Amendments were violated by Jail staff Diane Snow, RN, and Christina Watson, LPN. Randy had been booked into the Jail without his essential medications for heart disease, diabetes, high blood pressure, and a psychiatric disorder. Despite multiple requests, he did not receive all necessary medications, leading to his death from hypertensive cardiovascular disease.The United States District Court for the Northern District of Ohio denied Snow and Watson's motion for summary judgment, which sought dismissal based on qualified immunity. The court found that there were genuine disputes of material fact regarding whether Snow and Watson were aware of the substantial risk to Randy's health and whether they failed to respond reasonably.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Snow and Watson were not entitled to qualified immunity. The court found that both nurses were aware of Randy's serious medical conditions and the need for continuous medication. Despite this knowledge, they failed to ensure that Randy received his essential medications in a timely manner. The court concluded that their actions were unreasonable and violated Randy's constitutional rights. The court affirmed the district court's decision and remanded the case for further proceedings on the Estate's § 1983 claim. View "Wiertella v. Lake County" on Justia Law

Robert Carbone, a Connecticut resident, sued two Swiss organizations and several individuals from California, Illinois, and Switzerland for defamation and other tortious conduct. Carbone, a member of the two Swiss organizations, claimed that the defendants used websites to publish defamatory statements about him and facilitate his removal from the organizations. He filed the lawsuit in Ohio, arguing that the defamatory statements passed through servers located in Ohio, which hosted the organizations' websites.The United States District Court for the Southern District of Ohio dismissed Carbone's complaint for lack of personal jurisdiction. The court found that Carbone failed to establish that the defendants had sufficient contacts with Ohio to justify the court's jurisdiction over them. The defendants had not purposefully availed themselves of the privilege of acting in Ohio, as the servers' location in Ohio was chosen by third parties, not the defendants.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the defendants did not purposefully avail themselves of the privilege of acting in Ohio, as their only connection to the state was the location of the servers, which was a decision made by third parties. The court also found that Carbone's claims did not arise from the defendants' activities in Ohio, as the allegedly defamatory statements were not directed at Ohio or its residents. Therefore, the exercise of personal jurisdiction over the defendants in Ohio would not comply with the Due Process Clause. View "Carbone v. Kaal" on Justia Law