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

Donna Vanek, an employee of a construction company, was driving her personal Kia Optima to pick up supplies when a semitruck struck her car, killing her and her young nephew. The company’s Ford F-250, which Vanek would have used for the task, was in the repair shop at the time. The estates of Vanek and her nephew sued Ohio Casualty Insurance Company, arguing that the Kia qualified as a "temporary substitute" for the F-250 under the company’s insurance policy.The United States District Court for the Eastern District of Kentucky granted summary judgment to Ohio Casualty, ruling that the Kia did not qualify as a "temporary substitute" under the policy. The court accepted Ohio Casualty’s interpretation that a non-covered vehicle could not be a "temporary substitute" unless all covered vehicles were out of service.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 reasonable jury could find that the Kia qualified as a "temporary substitute" for the F-250. The court noted that witnesses testified Vanek would have used the F-250 if it had been available and that the Kia was used temporarily while the F-250 was in the shop. The court rejected Ohio Casualty’s interpretation that all covered vehicles must be out of service for a vehicle to qualify as a "temporary substitute," finding no basis for this in the policy’s text. The case was remanded for further proceedings consistent with this opinion. View "Olenik v. Ohio Casualty Insurance Co." on Justia Law

Aimee Sturgill, a registered nurse and devout Christian, objected to the American Red Cross's COVID-19 vaccination mandate, citing her religious beliefs. She requested a religious exemption, explaining that her faith required her to treat her body as a temple and avoid defiling it with the vaccine, which she believed could cause harm due to her blood clotting disorder. The Red Cross denied her request, stating that her objections were medically, not religiously, based and terminated her employment.The United States District Court for the Eastern District of Michigan dismissed Sturgill's complaint under Federal Rule of Civil Procedure 12(b)(6). The court held that she did not plausibly allege a prima facie case for a failure-to-accommodate claim under Title VII of the Civil Rights Act of 1964. The court also concluded that Sturgill did not set forth a separate disparate-treatment claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred by requiring Sturgill to establish a prima facie case at the pleading stage, which is not necessary under the plausibility standard set by Twombly and Iqbal. The appellate court found that Sturgill's complaint plausibly alleged that her refusal to take the COVID-19 vaccine was an aspect of her religious observance or belief. However, the court agreed with the district court that Sturgill's complaint did not set forth a standalone disparate-treatment claim. Consequently, the Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. View "Sturgill v. American Red Cross" on Justia Law

A group of consumers who purchased or leased 2011-2016 GM Silverado or Sierra trucks with Duramax diesel engines sued General Motors LLC and Robert Bosch entities. They alleged that GM falsely advertised the trucks as having "clean diesel" technology with low emissions, while the vehicles actually emitted pollutants at levels much higher than advertised and above EPA standards. The plaintiffs claimed violations of state consumer protection laws, fraud, deceptive trade practices, and the Racketeer Influenced and Corrupt Organizations (RICO) Act.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the defendants. The court found that the plaintiffs' state-law claims were preempted by the Clean Air Act (CAA) and that the plaintiffs lacked standing to bring RICO claims because they were indirect purchasers.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the plaintiffs' state-law claims were not preempted by the CAA. The court distinguished this case from a previous decision, In re Ford Motor Co. F-150 and Ranger Truck Fuel Economy Marketing and Sales Practices Litigation, noting that the plaintiffs' claims did not challenge EPA determinations but rather focused on GM's misleading advertisements to consumers. The court emphasized that the state-law claims were based on traditional state tort law and did not depend on proving fraud against the EPA.However, the court affirmed the district court's decision regarding the RICO claims. The court held that the plaintiffs, as indirect purchasers, lacked standing to bring RICO claims under the indirect-purchaser rule, which bars suits by consumers who are two or more steps removed from the violator in a distribution chain.In conclusion, the Sixth Circuit reversed the district court's grant of summary judgment on the state-law claims, allowing those claims to proceed, but affirmed the summary judgment on the RICO claims, barring those claims. View "Fenner v. General Motors, LLC" on Justia Law

John O’Hara pleaded guilty to wire fraud and bank fraud for misappropriating funds from his mother, Sally Thrush. Thrush passed away shortly after his plea, leaving O’Hara as the sole beneficiary of her estate. At sentencing, the district court ordered O’Hara to pay over $300,000 in restitution to Thrush’s estate, despite knowing that O’Hara would likely receive the restitution as the estate’s beneficiary. Four years later, the district court amended the judgment to direct O’Hara to pay the federal Crime Victims Fund instead of the estate.The United States District Court for the Eastern District of Kentucky initially sentenced O’Hara to twenty-six months in prison and ordered him to pay restitution to his mother’s estate. After O’Hara’s release from prison, the district court, prompted by the government, amended the judgment to substitute the Crime Victims Fund as the payee, reasoning that allowing O’Hara to receive his own restitution would be contrary to the intent of the Mandatory Victims Restitution Act (MVRA).The United States Court of Appeals for the Sixth Circuit reviewed the case and determined that the district court did not have the authority to modify the final judgment to substitute a new payee. The appellate court held that the MVRA, specifically 18 U.S.C. § 3663A(a)(2), does not provide the statutory authority to amend a restitution order post-judgment. The court emphasized that a final restitution order can only be modified under specific statutory provisions, none of which applied in this case. Consequently, the Sixth Circuit reversed the district court’s decision and remanded the case. View "United States v. O'Hara" on Justia Law

Thomas Merck applied for an entry-level position at Walmart and was given a conditional job offer pending a background check. Merck failed to disclose an old misdemeanor conviction, which was discovered during the background check. Walmart, through a third-party vendor, provided Merck with an incomplete version of the report, which indicated he was "not competitive" for the job. Walmart then revoked the job offer. Merck claimed that Walmart violated the Fair Credit Reporting Act by not providing him with the full consumer report before taking adverse action.The United States District Court for the Southern District of Ohio initially denied Walmart's motion to dismiss, finding that Merck had standing based on a procedural violation of the Act. However, after the Supreme Court's decision in TransUnion LLC v. Ramirez, which clarified the requirements for standing under the Fair Credit Reporting Act, Walmart renewed its motion for summary judgment. The district court granted the motion, concluding that Merck had not demonstrated a concrete injury as required by TransUnion.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Merck failed to show he suffered adverse effects from the denial of the full consumer report. Specifically, Merck did not provide evidence that he could have used the withheld information to his benefit, such as changing the outcome of his job application or affecting his subsequent job search. The court also rejected Merck's analogy to procedural due process claims and traditional common-law harms, finding that the statutory duty under the Fair Credit Reporting Act did not closely resemble these traditional harms. Therefore, Merck did not have constitutional standing to sue Walmart. View "Merck v. Walmart, Inc." on Justia Law

Two employees, Tanika Parker and Andrew Farrier, participated in 401(k) plans managed by subsidiaries of Tenneco Inc. The plans were amended to include mandatory individual arbitration provisions, which required participants to arbitrate disputes individually and barred representative, class, or collective actions. Parker and Farrier alleged that the fiduciaries of their plans breached their fiduciary duties under ERISA by failing to prudently manage the plans, resulting in higher costs and reduced retirement savings. They sought plan-wide remedies, including restitution of losses and disgorgement of profits.The United States District Court for the Eastern District of Michigan denied the fiduciaries' motion to compel individual arbitration. The court found that the arbitration provisions limited participants' substantive rights under ERISA by eliminating their ability to bring representative actions and seek plan-wide remedies, which are guaranteed by ERISA.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 the individual arbitration provisions were unenforceable because they acted as a prospective waiver of the participants' statutory rights and remedies under ERISA. The court emphasized that ERISA allows participants to sue on behalf of a plan and obtain plan-wide relief, and the arbitration provisions' restrictions on representative actions and plan-wide remedies violated these statutory rights. Consequently, the arbitration provisions were invalid, and the district court's judgment was affirmed. View "Parker v. Tenneco, Inc." on Justia Law

Joel M. Guy, Jr. murdered his parents in 2016 with the intent to collect the proceeds from his mother’s insurance plans. His mother had life insurance and accidental death and dismemberment insurance through her employer, naming Guy and his father as beneficiaries. Guy was convicted of first-degree premeditated murder, felony murder, and abuse of a corpse by a Tennessee jury.The United States District Court for the Eastern District of Tennessee determined that Guy would be entitled to the insurance proceeds if not disqualified. However, the court ruled that Guy was disqualified under Tennessee’s slayer statute or federal common law, which prevents a murderer from benefiting from their crime. The court granted summary judgment in favor of Guy’s family members, who argued that Guy was not entitled to the benefits. Guy appealed, arguing that ERISA preempts Tennessee’s slayer statute and that no federal common-law slayer rule applies.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that ERISA does not explicitly address the issue of a beneficiary who murders the insured, and thus, either Tennessee law or federal common law must apply. The court found that both Tennessee’s slayer statute and federal common law would disqualify Guy from receiving the insurance proceeds. The court affirmed the district court’s decision, concluding that Guy’s actions disqualified him from benefiting from his mother’s insurance plans under both state and federal law. View "Standard Insurance Co. v. Guy" on Justia Law

Adam N. Berry alleged that Experian Information Solutions, a consumer reporting agency, negligently or willfully published inaccurate information in his consumer report, indicating he owed spousal and child support. Berry provided Experian with court orders that purportedly showed he had no outstanding support obligations, but Experian continued to report a balance due as indicated by the Michigan Office of Child Support (OCS).The United States District Court for the Eastern District of Michigan granted Experian’s motion for judgment on the pleadings. The district court reasoned that the Fair Credit Reporting Act (FCRA) required Experian to report any information received from OCS about Berry’s failure to pay support. The court concluded that because Experian was required to report the unpaid balance and had verified the information’s accuracy with OCS, Berry’s claims were not actionable.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 Berry sufficiently pleaded that Experian did not adopt reasonable procedures to ensure maximum possible accuracy and did not reasonably reinvestigate Berry’s consumer report after he challenged its accuracy. The court emphasized that the FCRA requires consumer reporting agencies to adopt reasonable procedures to assure maximum possible accuracy and to conduct a reasonable reinvestigation if a consumer disputes the report’s accuracy. The court found that Experian’s reliance on automated verification with OCS, without further investigation into the court orders provided by Berry, was insufficient. The case was remanded for further proceedings consistent with the appellate court’s opinion. View "Berry v. Experian Information Solutions" on Justia Law

Don Ellis committed a carjacking and bank robbery in Toledo, Ohio, on August 13, 2018. He threatened a gas station customer with a gun, stole a car and $200, and later robbed a Fifth Third Bank. The police tracked him using a GPS device hidden in the stolen money, leading to a high-speed chase and his arrest. Ellis escaped from jail two days later but was recaptured five days after that. A federal grand jury indicted him on six counts, including carjacking, bank robbery, escape, unlawful firearm possession, and two counts of using or carrying a firearm during a crime of violence.The United States District Court for the Northern District of Ohio accepted Ellis's guilty plea to all six counts under a plea agreement, which included a waiver of his right to appeal except under specific circumstances. Ellis later moved to withdraw his plea, arguing he did not understand the appeal waiver's implications. The district court denied his motion, finding that he had been adequately informed of his rights and the plea agreement's terms. At sentencing, the court rejected Ellis's argument that the indictment failed to state a § 924(c) offense and sentenced him to 201 months in prison, as agreed in the plea deal.The United States Court of Appeals for the Sixth Circuit reviewed the case. Ellis argued that he should have been allowed to withdraw his plea and that the indictment was flawed. However, the court found that Ellis had knowingly and voluntarily waived his right to appeal as part of his plea agreement. The court also held that the alleged indictment error did not affect the district court's jurisdiction and could be waived. Consequently, the Sixth Circuit granted the government's motion to dismiss Ellis's appeal. View "United States v. Ellis" on Justia Law

Wade Jones was incarcerated at the Kent County Correctional Facility for five days in April 2018. During his incarceration, he experienced severe alcohol withdrawal symptoms. Despite being placed on an alcohol-withdrawal protocol, Jones did not receive timely or adequate medical care. On April 27, 2018, Jones went into cardiac arrest and was later transferred to a hospital, where he died a week later. His estate sued Kent County and several nurses, alleging deliberate indifference to his medical needs.The United States District Court for the Western District of Michigan held a trial where a jury found that nurses Melissa Furnace, Chad Goetterman, and James Mollo were deliberately indifferent to Jones’s medical condition, which was a proximate cause of his death. The jury awarded Jones’s estate $6.4 million in compensatory damages. The defendants moved for judgment as a matter of law or a new trial, arguing that the jury’s verdict was inconsistent, that no reasonable jury could find proximate cause, that the estate’s counsel engaged in misconduct, and that a juror’s failure to disclose his criminal history warranted a new trial. The district court denied these motions.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the defendants had forfeited their inconsistent-verdict argument by not objecting before the jury was discharged. It also found sufficient evidence to support the jury’s finding of proximate cause, noting that the jury could reasonably conclude that the nurses’ failure to provide timely medical care significantly decreased Jones’s likelihood of survival. The court further held that the estate’s counsel’s emotional display during trial did not constitute contumacious conduct warranting a new trial. Lastly, the court found no basis for a new trial due to juror misconduct, as the juror was never directly asked about his own criminal history during voir dire. View "Jones v. Kent County" on Justia Law