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

After the death of Marjorie Johnson in 2020, her daughter, Rita Johnson, was appointed as executrix of her estate by the Wayne County, Michigan probate court. Rita initiated probate proceedings to determine whether certain assets belonged to the estate or to the Johnson Family Trust, which had a provision requiring arbitration of disputes. Amos C. Johnson, Marjorie’s son and trustee of the Trust, sought to compel arbitration in state court, but the request was denied. Subsequently, Amos and the Trust filed suit in the United States District Court for the Eastern District of Michigan, seeking to compel arbitration of the probate dispute under § 4 of the Federal Arbitration Act (FAA).The district court ordered the plaintiffs to show cause why the case should not be dismissed for lack of subject matter jurisdiction, citing the probate exception, the prior-exclusive-jurisdiction doctrine, and potential lack of diversity. The court ultimately dismissed the case, finding that the FAA does not provide an independent basis for federal question jurisdiction and that the probate proceedings were in rem, meaning the federal court would improperly interfere with property under the state probate court’s control.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit held that federal courts may only compel arbitration under § 4 of the FAA if they would have jurisdiction over the underlying dispute. Because the probate proceedings were purely matters of state law and involved property already under the state court’s jurisdiction, the federal court lacked both federal question and diversity jurisdiction. The Sixth Circuit affirmed the district court’s dismissal, holding that the federal court did not have subject matter jurisdiction to compel arbitration of the state probate proceedings. View "Johnson v. Johnson" on Justia Law

The defendant was apprehended after two separate incidents in which he was found in possession of firearms and drugs. In the first incident, after a car accident, he attempted to dissuade the other driver from calling the police due to the presence of contraband in his vehicle, then fled but was quickly caught. In the second incident, a traffic stop led to the discovery of additional firearms, ammunition, and drugs. He was charged with two counts of possessing a firearm as a convicted felon and pleaded guilty.The United States District Court for the Eastern District of Kentucky calculated his base offense level under the Sentencing Guidelines as twenty-two, based in part on a prior Kentucky conviction for second-degree manslaughter, which the court classified as a “crime of violence.” The defendant did not object to this calculation at sentencing and was sentenced to 145 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Kentucky’s second-degree manslaughter qualifies as a “crime of violence” under the Sentencing Guidelines, applying plain error review because the issue was not raised below. The court held that the Kentucky statute’s “wantonness” mens rea is functionally equivalent to “recklessness” as defined in Borden v. United States, 593 U.S. 420 (2021), and does not meet the standard for a “crime of violence,” which requires purposeful or knowing conduct. The court found that the district court’s reliance on this conviction to enhance the sentence was plain error, affected the defendant’s substantial rights, and undermined the fairness of the proceedings. Accordingly, the Sixth Circuit vacated the sentence and remanded for resentencing. View "United States v. Tooley" on Justia Law

Andrew Maurice Randolph was convicted in Michigan state court of second-degree murder and weapons offenses after a shooting at his former girlfriend’s home resulted in the death of her mother. The prosecution’s case relied heavily on ammunition found in Randolph’s bags at his father’s house and a firearm discovered at his brother’s residence, which was identified as the murder weapon. Randolph’s trial counsel did not move to suppress this evidence, and Randolph argued that this failure, among other alleged deficiencies, constituted ineffective assistance of counsel.Following his conviction, Randolph appealed to the Michigan Court of Appeals, which rejected his ineffective assistance claim without explanation. The Supreme Court of Michigan reversed in part for unrelated reasons and remanded. On remand, the Michigan Court of Appeals affirmed the conviction, finding Randolph did not demonstrate a reasonable expectation of privacy in the searched belongings. The Supreme Court of Michigan denied leave to appeal. Randolph then sought federal habeas relief in the United States District Court for the Eastern District of Michigan, raising four ineffective assistance claims. The district court denied the petition, concluding that the suppression motion would have failed and that counsel’s other actions were either strategically reasonable or not prejudicial. The district court also denied a certificate of appealability (COA).On appeal, the United States Court of Appeals for the Sixth Circuit reviewed only the claim that trial counsel was ineffective for failing to move to suppress evidence obtained from the search of Randolph’s belongings, as this was the sole issue for which a COA was granted. The Sixth Circuit held that the state court’s factual findings and legal conclusions were reasonable under the Antiterrorism and Effective Death Penalty Act (AEDPA) and affirmed the district court’s denial of habeas relief. The court also denied Randolph’s request to expand the COA, holding that a merits panel lacks authority to do so. View "Randolph v. Macauley" on Justia Law

Two individuals were involved in a drug-trafficking operation distributing fentanyl and methamphetamine in the Lexington, Kentucky area. One supplied the drugs, which were pressed to resemble oxycodone pills, to the other, who then sold them to others. Both were apprehended after law enforcement used confidential informants and controlled buys. The supplier pleaded guilty to drug and firearm offenses, while the other pleaded guilty to conspiracy to distribute drugs.The United States District Court for the Eastern District of Kentucky sentenced the supplier to 228 months in prison and the other individual to 74 months, also imposing supervised release conditions. Both defendants challenged the procedural reasonableness of their sentences, specifically contesting the application of a sentencing enhancement under U.S.S.G. § 2D1.1(b)(13) for knowingly misrepresenting or marketing fentanyl as another substance. The second defendant also argued ineffective assistance of counsel, improper denial of a downward departure for reduced mental capacity, and an improper special condition of supervised release.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the district court properly applied the sentencing enhancement: the supplier knowingly misrepresented fentanyl as oxycodone, and the other knowingly marketed fentanyl as another substance, given the pills’ appearance and his knowledge of their contents. The court found no error in the district court’s reliance on a cooperating witness’s statement or in its findings regarding the defendants’ knowledge. The appellate court declined to address the ineffective assistance claim on direct appeal due to an insufficient record, found the denial of a downward departure unreviewable, and upheld the special condition of supervised release. The Sixth Circuit affirmed the district court’s judgments. View "United States v. Matthews" on Justia Law

A man walking along the shoulder of a Nashville interstate was approached by a state trooper, who intended to pat him down and offer a ride. During the encounter, the man produced a box cutter, failed to comply with repeated police commands, and a standoff ensued involving multiple officers from different agencies. After about thirty-five minutes, the man took two quick steps toward the officers, pulled an object from his pocket, and pointed it at them in a manner resembling a firearm. In response, nine officers fired approximately thirty-three shots, twelve of which struck and killed him. Notably, after the man had fallen to the ground and appeared incapacitated, one officer fired two additional shots.The decedent’s wife filed suit in the United States District Court for the Middle District of Tennessee against the involved cities and officers, alleging excessive force in violation of the Fourth Amendment. The officers moved to dismiss the complaint on the basis of qualified immunity. The district court denied the motions, finding that the complaint plausibly alleged a constitutional violation and that the right at issue was clearly established. The court also determined that video evidence did not blatantly contradict the plaintiff’s allegations regarding the officers’ conduct after the man was incapacitated.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that eight of the nine officers were entitled to qualified immunity because their initial use of deadly force was objectively reasonable under the circumstances. However, the court found that the officer who fired two shots after the man was incapacitated was not entitled to qualified immunity at this stage, as the complaint plausibly alleged a violation of clearly established law prohibiting the use of force against a neutralized suspect. The court affirmed in part and reversed in part. View "Eastep v. City of Nashville" on Justia Law

Officers investigating a drug trafficking ring observed Devin Long engaging in several suspected drug transactions, including controlled buys involving other individuals. Surveillance revealed Long’s repeated visits to known stash houses and his own registered residence, where officers witnessed activity consistent with drug dealing. Based on these observations and information from a confidential source, officers obtained a warrant to search Long’s home. The search uncovered illegal drugs, firearms, and related paraphernalia, leading to Long’s indictment on federal drug and firearm charges.The United States District Court for the Northern District of Ohio reviewed Long’s motion to suppress the evidence seized from his home, which argued that the affidavit supporting the search warrant failed to establish a sufficient nexus between his alleged criminal activity and the residence. The district court denied the motion, finding that the affidavit provided probable cause for the search. Long subsequently pleaded guilty to four charges but preserved his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Sixth Circuit considered whether the search warrant for Long’s home was supported by probable cause. Applying a deferential standard to the issuing magistrate judge’s determination, the Sixth Circuit held that the affidavit established both that Long’s home was his residence and that he was engaged in ongoing drug trafficking. The court further found that even a single drug transaction observed outside Long’s home provided an independent basis for probable cause. The court affirmed the district court’s denial of Long’s motion to suppress, concluding that the warrant was properly issued under the Fourth Amendment. View "United States v. Long" on Justia Law

A former correctional officer with the Michigan Department of Corrections was terminated after a coworker accused him of making harassing and inappropriate comments. The officer, after being served with a misconduct charge and attending a disciplinary conference with his union representative, was formally terminated in July 2019. He challenged his termination through arbitration, which concluded in December 2020 with a decision upholding his dismissal. Nearly three years later, he filed a federal lawsuit against two department officials, alleging violations of his constitutional rights under 42 U.S.C. § 1983, specifically focusing on procedural due process.The United States District Court for the Western District of Michigan initially dismissed the officer’s first complaint without prejudice for lack of prosecution after he failed to respond to a motion to dismiss. When he refiled a similar complaint, the district court dismissed it again, this time on the grounds that the claim was untimely under Michigan’s three-year statute of limitations for personal injury actions and that, except for his procedural due process claim, he had forfeited his other constitutional arguments. The court also found that his procedural due process claim failed to state a claim upon which relief could be granted.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that the officer’s procedural due process claim accrued, at the latest, on the date of his post-termination arbitration hearing in December 2020, making his June 2024 complaint untimely. The court further held that Michigan law does not permit equitable tolling of the statute of limitations in this context and that the officer failed to plausibly allege inadequate process either before or after his termination. The Sixth Circuit affirmed the district court’s dismissal. View "Bozzo v. Nanasy" on Justia Law

A Guatemalan national entered the United States without authorization after fleeing gang violence in his home country. He sought asylum, withholding of removal, and protection under the Convention Against Torture, but an immigration judge denied these requests and ordered his removal. The Board of Immigration Appeals affirmed the removal order. Following the Supreme Court’s decision in Niz-Chavez v. Garland, which clarified the requirements for a valid “notice to appear,” the petitioner moved to reopen his removal proceedings to seek voluntary departure, a form of relief that would allow him to leave the United States without a formal removal order. To qualify, he needed to show, among other things, that he had the means to depart the country, typically by possessing a valid passport.The Board of Immigration Appeals denied his motion to reopen, finding that his affidavit—stating only that he was in the process of renewing his Guatemalan passport—was too conclusory and unsupported by documentary evidence. The Board concluded that he had not sufficiently demonstrated that he would be able to depart the United States if granted voluntary departure.The United States Court of Appeals for the Sixth Circuit reviewed the Board’s denial. The court held that the Board applied the correct legal standard, requiring only a prima facie showing of eligibility for relief at the motion-to-reopen stage, not conclusive proof. The court found that the Board did not err in determining that the petitioner’s unsupported and conclusory statement about his passport application failed to meet even this threshold. The Sixth Circuit therefore denied the petition for review, upholding the Board’s decision. View "Pastor-Hernandez v. Bondi" on Justia Law

Kenneth Evans was observed by police engaging in a hand-to-hand transaction in a vehicle. Upon approaching the vehicle, officers detected the smell of marijuana, searched the car, and found a loaded pistol. Evans admitted to handling the firearm and being on parole. He was subsequently indicted by a federal grand jury for being a felon in possession of a firearm and ammunition, to which he pleaded guilty. Evans had prior felony convictions, including one for aggravated robbery under Ohio law.The United States District Court for the Northern District of Ohio determined that Evans’s prior aggravated robbery conviction qualified as a “crime of violence” under the United States Sentencing Guidelines. This finding increased his advisory sentencing range from 24–30 months to 46–57 months, and the court sentenced him to 57 months’ imprisonment. Evans appealed, arguing that his aggravated robbery conviction should not be considered a crime of violence for sentencing purposes.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s legal determination de novo. The appellate court applied the categorical and modified categorical approaches to compare the elements of Ohio’s aggravated robbery statute, as applied to Evans’s conviction, with the definition of “extortion” in the Sentencing Guidelines. The court concluded that aggravated robbery under Ohio Revised Code § 2911.01(A)(1), when predicated on theft, categorically matches the Guidelines’ definition of extortion and therefore constitutes a crime of violence. The court rejected Evans’s arguments to the contrary and affirmed the district court’s judgment, upholding the increased sentence. The court also granted the government’s motion to take judicial notice. View "United States v. Evans" on Justia Law

Four defendants were members of a Detroit-based gang involved in drug distribution and violent crimes, including homicides, during the 1980s and 1990s. They were indicted in 1995 for conspiracy to distribute cocaine and crack cocaine, intentional killings in furtherance of a continuing criminal enterprise, and firearms offenses. Juries convicted all four on all counts in two separate trials. The district court sentenced each to concurrent life terms for the drug and homicide convictions, plus consecutive terms for the firearms offenses, following the then-mandatory Sentencing Guidelines. Their convictions and sentences were affirmed on appeal.Years later, after Congress enacted the Fair Sentencing Act and the First Step Act, which allowed for reduced sentences for certain crack cocaine offenses, the defendants moved for sentence reductions under the First Step Act. The United States District Court for the Eastern District of Michigan initially denied some motions, reasoning that the homicide convictions were not “covered offenses” under the Act. On appeal, the United States Court of Appeals for the Sixth Circuit vacated the denial as to the drug conspiracy count for one defendant, holding he was eligible for a reduction on that count. On remand, the district court reduced the sentences for both the drug and homicide convictions for all four defendants, concluding it had discretion to do so under the First Step Act and the sentencing-package doctrine.The United States Court of Appeals for the Sixth Circuit held that the First Step Act authorizes a district court to reduce a sentence for a non-covered offense only if it was part of a sentencing package with a covered offense. The court vacated the reduced sentences and remanded for the district court to determine whether the homicide sentences were truly part of such a sentencing package with the covered drug offense, and to proceed accordingly. View "United States v. Dale" on Justia Law