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

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

Next Century Rebar, LLC (NCR) worked on a project in Detroit, Michigan, within the jurisdiction of Local Union Number 25 (Local 25). Due to a shortage of Local 25 iron workers, NCR hired workers from out-of-state unions, Local 416 and Local 846. NCR made benefits contributions to the funds associated with these out-of-state unions. In 2021, Local 25 Funds conducted an audit and found that NCR had not made contributions to the Local 25 Funds for these out-of-state employees. NCR contested this, arguing that it had already made contributions to the out-of-state funds.The Local 25 Funds filed a lawsuit under 29 U.S.C. § 1145, seeking unpaid contributions. The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Local 25 Funds, awarding them $1,787,300.75 in unpaid contributions, $143,075.41 in interest, and $288,598.80 in liquidated damages. The court also awarded $18,233.15 in costs and $99,812.25 in attorney fees. NCR appealed, arguing that the district court applied the wrong summary-judgment standard, improperly granted summary judgment despite genuine disputes of material fact, and abused its discretion by not awarding a setoff for contributions made to out-of-state funds.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Local 25 CBA required contributions based on the specific employee’s gross earnings for the vacation fund and base wages for the pension fund. However, it was unclear whether the audit used the correct wage rates. The court also found that the Local 25 Funds' request for contributions violated the International Agreement’s prohibition on double payments. Consequently, the court affirmed the district court’s decision in part, reversed it in part, and remanded the case for further proceedings. View "Trustees of Iron Workers Defined Contribution Pension Fund v. Next Century Rebar, LLC" on Justia Law

In January 2019, Ashley Franklin, an inmate at the Franklin County Regional Jail, was transported to a hospital by Jail Sergeant Brandon Price due to illness. During the transport, Price sexually assaulted Franklin. Franklin filed a lawsuit against Price, Franklin County, and two other Jail employees, asserting constitutional claims under 42 U.S.C. § 1983 and related state law claims. She alleged that Price and his superior, Captain Wes Culbertson, were deliberately indifferent to her safety and that Franklin County had inadequate policies and training to prevent such assaults.The United States District Court for the Eastern District of Kentucky granted Franklin’s motion for summary judgment on her Eighth Amendment claim against Price but denied her other claims. The court granted summary judgment in favor of the other defendants, finding no evidence that Culbertson or Franklin County were deliberately indifferent or that the County’s policies were inadequate. The court also found that the County’s previous incidents of misconduct did not establish a pattern of unconstitutional behavior. Franklin’s negligence claims against Culbertson and Jailer Rick Rogers were dismissed, with the court ruling that they were entitled to qualified immunity under Kentucky law.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The appellate court held that Franklin County was not liable under § 1983 because Franklin failed to show a direct causal link between the County’s policies and her assault. The court also found that Culbertson and Rogers were entitled to qualified immunity, as their actions were discretionary and performed in good faith. Franklin’s claims of gross negligence were deemed forfeited due to lack of development in her arguments. The court concluded that Franklin had not established that the County’s policies or training were constitutionally inadequate or that there was a pattern of similar constitutional violations. View "Franklin v. Franklin County" on Justia Law

In this case, DEA agents, acting on an anonymous tip, conducted a four-month investigation into Robert Cortez Burrell's alleged drug trafficking activities. They surveilled Burrell, observed suspicious behavior consistent with drug transactions, and corroborated the tip with additional evidence, including Burrell's criminal history and interactions with known drug dealers. Based on this information, they obtained and executed search warrants for four residences associated with Burrell, recovering significant quantities of illegal narcotics, firearms, and drug-manufacturing equipment. Burrell was subsequently convicted by a jury of multiple drug-related offenses and being a felon in possession of firearms and ammunition, resulting in a 180-month prison sentence.The United States District Court for the Eastern District of Michigan denied Burrell's motion to suppress the evidence obtained from the searches, as well as his motion to dismiss the firearms and ammunition charges on Second Amendment grounds. The court found that the search warrants were supported by probable cause and that Burrell's motion to dismiss was untimely. Additionally, the court admitted testimony that Burrell argued violated the Confrontation Clause and the Federal Rules of Evidence.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's judgment. The appellate court held that the search warrants were supported by probable cause, as the DEA agents had sufficiently corroborated the anonymous tip through extensive surveillance and other investigative methods. The court also found that the district court did not abuse its discretion in denying Burrell's motion to dismiss as untimely and that Burrell's constitutional challenges to the firearms and ammunition charges failed under the plain-error standard. Furthermore, the court ruled that the admission of the contested testimony did not violate the Confrontation Clause or the Federal Rules of Evidence, as the statements were not offered for their truth but to explain the DEA's actions. View "United States v. Burrell" on Justia Law

The case involves Joseph Betro, Mohammed Zahoor, Tariq Omar, and Spilios Pappas, who conspired to defraud Medicare by administering medically unnecessary back injections and bribing patients with opioid prescriptions. They fraudulently billed these injections as “facet injections” to receive higher reimbursements. Additionally, they ordered unnecessary urine drug tests and referred patients to ancillary services in exchange for kickbacks. Despite patient complaints about the ineffectiveness and pain of the injections, the defendants continued their fraudulent practices.A jury in the United States District Court for the Eastern District of Michigan convicted the defendants of conspiracy to commit healthcare fraud and wire fraud under 18 U.S.C. § 1349 and healthcare fraud under 18 U.S.C. § 1347. The defendants filed motions for a new trial, which the district court denied. They then appealed their convictions and sentences, raising various challenges related to the prosecution, evidence admission, jury instructions, and sentencing calculations.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgments. The court found sufficient evidence to support the jury’s findings that the defendants knowingly participated in the fraudulent scheme. The court also held that the district court did not abuse its discretion in denying the motions for a new trial, admitting evidence, or instructing the jury. The sentences imposed were deemed procedurally and substantively reasonable, with the court noting that the district court had appropriately calculated the loss amounts and applied relevant sentencing enhancements. View "United States v. Betro" on Justia Law

The case involves an unfair labor practice dispute between Rieth-Riley Construction Co., a highway construction contractor in Michigan, and Local 324, International Union of Operating Engineers, AFL-CIO. The dispute centers on subcontracting and employee wages. The last collective-bargaining agreement expired on May 31, 2018, and despite multiple bargaining sessions, no successor agreement has been reached. The Union went on strike on July 31, 2019, and picketing incidents ensued, including an altercation where a striking union member, Michael Feighner, assaulted a truck driver, Karl Grinstern.The National Labor Relations Board (NLRB) General Counsel issued complaints against both parties: against the Union for picketing misconduct and against Rieth-Riley for failing to provide requested subcontracting and employee information. An Administrative Law Judge (ALJ) found that Rieth-Riley violated the National Labor Relations Act (NLRA) by not providing the requested information and that the Union violated the NLRA when Feighner assaulted Grinstern. The ALJ ordered Rieth-Riley to provide the requested information and the Union to cease and desist from such misconduct. The NLRB affirmed the ALJ’s decision with a slight modification.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that President Biden lawfully removed the NLRB General Counsel, and the General Counsel had unreviewable prosecutorial discretion. The court found substantial evidence supporting the ALJ’s conclusions that the requested information was relevant to the Union’s bargaining responsibilities and that Rieth-Riley’s refusal to provide it violated the NLRA. The court also upheld the finding that the Union’s assault on Grinstern was an unfair labor practice. The court denied Rieth-Riley’s petition for review and granted the NLRB’s cross-application for enforcement of its order in full. View "Rieth-Riley Construction Co. v. National Labor Relations Board" on Justia Law

In 1974, Regina Andrews was found murdered, and her husband, Isaiah Andrews, was convicted of the crime based on circumstantial evidence. After nearly 46 years in prison, Isaiah was granted a new trial in 2020 when it was discovered that exculpatory evidence had been withheld. A new jury acquitted him in 2021. Subsequently, Isaiah filed a § 1983 lawsuit against the City of Cleveland and several officers, alleging violations of his Fourteenth Amendment rights due to the suppression of exculpatory evidence.The United States District Court for the Northern District of Ohio dismissed Isaiah's claims against the estates of the deceased officers, William Hubbard and Ernest Rowell, citing that the claims were filed too late under Ohio law. The court also granted summary judgment in favor of the City of Cleveland, concluding that the police did not withhold exculpatory evidence from the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of claims against the estates of Hubbard and Rowell, agreeing that Isaiah's claims were untimely under Ohio law. However, the court reversed the summary judgment in favor of the City of Cleveland. The appellate court found that there was a material dispute of fact regarding whether the police had withheld a crucial page of a police report linking another suspect to the crime scene. The court remanded the case to the district court to determine whether a City policy caused the alleged Brady violation. View "Estate of Andrews v. City of Cleveland" on Justia Law

Joseph Fortin applied for disability insurance benefits, but his claim was denied by an Administrative Law Judge (ALJ) from the Social Security Administration (SSA). Fortin argued that the ALJ who denied his claim was improperly appointed because the then-Acting Commissioner of the SSA, Nancy Berryhill, lacked the authority to ratify the ALJ's appointment. Fortin did not challenge the merits of the ALJ's decision but focused on the validity of the ALJ's appointment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Commissioner of Social Security, rejecting Fortin's arguments. The court held that Berryhill's ratification of the ALJ's appointment was valid and that the ALJ did not err in denying Fortin's application for benefits.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Berryhill, as Acting Commissioner, had the authority to ratify the appointments of SSA ALJs in response to the Supreme Court's decision in Lucia v. Securities and Exchange Commission, which required ALJs to be appointed in accordance with the Appointments Clause. The court also concluded that Berryhill's actions were valid under the Federal Vacancies Reform Act and that she did not need to be reappointed by the sitting President to serve as Acting Commissioner. The court found that Berryhill's ratification of the ALJ's appointment was both constitutionally and statutorily valid, and therefore, Fortin was not entitled to a new hearing before a different ALJ. View "Fortin v. Commissioner of Social Security" on Justia Law

Gregory D. Ralston was found guilty by a jury of distributing and possessing with intent to distribute a fentanyl-containing substance. He was acquitted of causing serious bodily injury by distributing the fentanyl. Ralston challenged the district court’s denial of his motion to suppress evidence without an evidentiary hearing, the limitation of his cross-examination of two government witnesses, and the reasonableness of his 180-month sentence.The United States District Court for the Northern District of Ohio initially scheduled an evidentiary hearing on Ralston’s motion to suppress but later denied the motion without holding the hearing. Ralston proceeded to trial, where the court limited his cross-examination of witnesses regarding potential bias and prior convictions. The jury convicted Ralston on the drug charges but acquitted him of the enhancement for causing serious bodily injury. The district court then imposed a 180-month sentence, significantly above the Guidelines range of 27 to 33 months, citing Ralston’s prior conviction and the seriousness of the current offense.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found no abuse of discretion in the district court’s decision to deny the motion to suppress without an evidentiary hearing, as the issues raised were legal rather than factual. The appellate court also upheld the limitation on cross-examination, noting that Ralston had the opportunity to question the witnesses directly about potential bias. The court found the sentence procedurally reasonable, as the district court adequately explained the upward variance and considered the § 3553(a) factors. The court also found the sentence substantively reasonable, given the district court’s rationale and the evidence supporting the findings.The Sixth Circuit affirmed the district court’s judgment but remanded the case for consideration of a potential sentence reduction under 18 U.S.C. § 3582(c) due to an intervening amendment in the Sentencing Guidelines. View "United States v. Ralston" on Justia Law