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

A student, C.M., experienced repeated racial harassment by peers while attending public school in Michigan, including being subjected to racial slurs, threats, and physical assault. The harassment occurred during her sixth, seventh, and ninth grades, prompting her to transfer to another school district in her freshman year. C.M. and her parents alleged that the school district and its officials failed to adequately respond to her complaints, asserting violations of federal law (Title VI of the Civil Rights Act and the Equal Protection Clause) and Michigan’s Elliott-Larsen Civil Rights Act.The United States District Court for the Eastern District of Michigan reviewed the case and granted summary judgment in favor of the school district and its officials. The district court found that, even when viewing the facts in the light most favorable to C.M., the school’s responses to the reported incidents did not amount to deliberate indifference under the applicable legal standards. C.M. appealed this decision to the United States Court of Appeals for the Sixth Circuit.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The appellate court assumed, without deciding, that deliberate indifference claims are cognizable under Title VI for student-on-student racial harassment. Applying the deliberate indifference standard, the court held that the school’s responses to each reported incident were not clearly unreasonable and reflected good faith efforts, including investigations, disciplinary actions, and proactive measures. The court concluded that C.M. failed to establish deliberate indifference, and therefore her claims under Title VI, the Equal Protection Clause, and the Elliott-Larsen Civil Rights Act could not succeed. The judgment of the district court was affirmed. View "Malick v. Croswell-Lexington Dist. Schs." on Justia Law

The petitioner, a taxpayer, received a notice of deficiency from the Internal Revenue Service (IRS) regarding her 2022 tax return. The IRS determined that she was not entitled to certain tax credits and imposed penalties. The notice, dated May 30, 2023, was sent to her former address, and she did not become aware of it until after the deadline to contest the deficiency had passed. She filed a petition for redetermination with the United States Tax Court on November 1, 2023, well after the ninety-day deadline specified in the Internal Revenue Code. In her petition, she argued that she was entitled to the disputed credits and status, and requested equitable tolling of the filing deadline due to her lack of timely notice.The United States Tax Court dismissed her petition for lack of jurisdiction, holding that the ninety-day deadline in I.R.C. § 6213(a) was a strict jurisdictional requirement that could not be extended or tolled, regardless of the circumstances. The court relied on prior Sixth Circuit precedent that had characterized the deadline as jurisdictional and rejected the petitioner’s arguments for equitable tolling.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the Tax Court’s dismissal de novo. The Sixth Circuit held that, in light of recent Supreme Court guidance, the ninety-day deadline in § 6213(a) is not a jurisdictional rule but rather a nonjurisdictional claims-processing rule. As such, it is presumptively subject to equitable tolling. The court reversed the Tax Court’s dismissal and remanded the case for the Tax Court to consider, in the first instance, whether the petitioner is entitled to equitable tolling of the filing deadline based on the specific facts of her case. View "Oquendo v. Comm'r of Internal Revenue" on Justia Law

A woman who had been living with a couple in Tennessee returned to their home to collect her belongings after being told she could no longer stay there. A dispute arose over the ownership of a car parked at the residence. The woman alleged that one of the residents, Matthew Howell, pointed a gun at her and refused to let her retrieve the car. She called 911, reporting the incident and stating that Howell was intoxicated and had threatened her. When police arrived, they spoke with the woman, who reiterated her allegations. Officers knocked on the door, and upon Howell opening it, they detected the smell of marijuana. The officers entered the home, arrested Howell for aggravated assault and resisting a frisk, and temporarily handcuffed his girlfriend, Alisha Brown, while conducting a protective sweep. The officers also allowed the woman to access the disputed car.Howell was indicted by a Tennessee grand jury for aggravated assault and resisting arrest. At trial, the jury convicted him of reckless aggravated assault, but the conviction was later amended to simple assault and ultimately reversed on double jeopardy grounds by an appellate court. Meanwhile, Howell and Brown filed a civil suit in the United States District Court for the Middle District of Tennessee, alleging Fourth Amendment violations and state tort claims against the officers and the Metropolitan Government of Nashville and Davidson County. The district court granted summary judgment to the defendants on the federal claims and declined to exercise jurisdiction over the state claims.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that the officers were entitled to qualified immunity on all federal claims. It found that the officers’ warrantless entry was not clearly established as unconstitutional under existing precedent, that probable cause supported Howell’s arrest, and that Brown’s temporary detention did not violate clearly established law. The court also found no clearly established law prohibiting the officers’ actions regarding the disputed car and rejected the malicious prosecution claim. The court affirmed summary judgment for the officers and municipality. View "Howell v. McCormick" on Justia Law

A businessman in the coal industry, John Siegel, used a network of family-owned companies to finance a project to develop a coal shipping terminal in Oakland, California. Over several years, Siegel directed one family company, Cecelia Financial Management, to advance funds to another, Insight Terminal Solutions, which was developing the terminal. These advances were documented as loans through promissory notes, but Siegel was involved on both sides of the transactions. After Insight filed for bankruptcy in 2019, Cecelia filed a claim as a creditor for over $6 million, asserting the advances were loans. However, the new owner of Insight, Autumn Wind, argued these were actually equity contributions, not loans, and sought to have the bankruptcy court recharacterize them as such, which would subordinate Cecelia’s claim.The United States Bankruptcy Court for the Western District of Kentucky held a trial to determine the nature of the advances. During the proceedings, Siegel died, and his deposition—taken before his death but without cross-examination by the opposing party—became central. The bankruptcy court excluded Siegel’s deposition, reasoning that the lack of cross-examination opportunity rendered it inadmissible, and ultimately ruled in favor of Bay Bridge Exports (which had acquired Cecelia’s claim), declining to recharacterize the advances as equity. The Bankruptcy Appellate Panel of the Sixth Circuit affirmed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. It held that the bankruptcy court committed legal error by categorically excluding Siegel’s deposition solely due to the absence of cross-examination, misinterpreting Federal Rule of Civil Procedure 32(a). The Sixth Circuit clarified that courts have discretion, not an absolute bar, in such circumstances. The court reversed the bankruptcy court’s decision and remanded for further proceedings, instructing the lower court to reconsider the admissibility of the deposition and, if admitted, its impact on the recharacterization analysis. View "Insight Terminal Solutions v. Cecelia Fin. Mgmt." on Justia Law

In early 2021, United States postal inspectors in Cleveland became suspicious of two packages sent between Ohio and California, both exhibiting characteristics commonly associated with drug trafficking, such as high cash-paid postage, mismatched sender and recipient information, and declined delivery signatures. After a certified narcotics detection dog named Ciga alerted to both packages, inspectors obtained search warrants and discovered a large sum of cash in one package and over a kilogram of fentanyl in the other. Subsequent investigation and a sting operation led to the arrest of Jaavaid McCarley-Connin, who was indicted on federal drug and firearm charges.The United States District Court for the Northern District of Ohio reviewed McCarley-Connin’s motions to suppress the evidence obtained from the package searches. He argued that, under Florida v. Harris, he was entitled to an evidentiary hearing to challenge the reliability of the canine’s alert, having presented extrinsic evidence to that effect. The government responded that Harris applied only to warrantless searches and that, for searches conducted pursuant to a warrant, a defendant must meet the requirements of Franks v. Delaware to obtain such a hearing. The district court agreed with the government, denied the evidentiary hearing and suppression motions, and McCarley-Connin subsequently pleaded guilty while reserving his right to appeal the suppression ruling.On appeal, the United States Court of Appeals for the Sixth Circuit held that Florida v. Harris does not entitle a defendant to an evidentiary hearing or consideration of extrinsic evidence regarding a canine’s reliability when the search is conducted pursuant to a warrant. Instead, the Franks v. Delaware standard governs such challenges. Because McCarley-Connin did not request a Franks hearing, the appellate court affirmed the district court’s denial of his motions and concluded that the search warrants were supported by probable cause. View "United States v. McCarley-Connin" on Justia Law

William Plott suffered severe, lifelong disabilities as a result of a vaccine administered in infancy. His family sought compensation under the National Vaccine Injury Compensation Program, filing a petition in the United States Court of Federal Claims. A special master determined that Plott’s parents were entitled to monetary relief for his care and ordered the Department of Health and Human Services (HHS) to pay a lump sum and to purchase an annuity from Wilcac Life Insurance Company, with annual payments to be made to Plott’s estate. After Plott’s death, his estate sought a final annuity payment, which Wilcac refused to pay, prompting the estate to sue both HHS and Wilcac.The estate initially filed suit in the Hamilton County, Ohio, Court of Common Pleas. Wilcac removed the case to the United States District Court for the Southern District of Ohio. HHS moved to dismiss for lack of subject matter jurisdiction, and the district court granted this motion, dismissing HHS from the case. Wilcac then argued that HHS was a necessary and indispensable party under Federal Rule of Civil Procedure 19, and the district court agreed, dismissing the entire case without prejudice because HHS could not be joined without defeating subject matter jurisdiction.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s application of Rule 19. The appellate court held that the district court erred by applying a bright-line rule that all parties to a contract are necessary and indispensable under Rule 19. Instead, the court emphasized that Rule 19 requires a pragmatic, case-specific analysis. The Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings, instructing the lower court to conduct a proper Rule 19 analysis based on the specific facts of the case. View "Estate of William Plott v. Health and Human Services" on Justia Law

A physician who worked at several cancer centers in Kentucky brought a lawsuit under the False Claims Act, alleging that his former employers fraudulently billed Medicare and other federal programs. He claimed that the centers submitted claims falsely representing that radiation and chemotherapy services were either supervised or performed by qualified physicians, when in fact, they were not. The allegations included both radiation services and chemotherapy services, with the core assertion being that the centers either lacked proper physician supervision or used unqualified personnel, and that this resulted in improper billing to federal programs.The United States District Court for the Eastern District of Kentucky initially dismissed some of the physician’s claims and, after discovery, granted summary judgment to the defendants on the remaining claims. The court found that the plaintiff failed to show that Medicare required the specific type of physician supervision he alleged for radiation services, and that he did not provide sufficient evidence of any specific fraudulent chemotherapy claims. The court also determined that the plaintiff’s analysis of schedules and staffing was unreliable and speculative, and that he could not identify a single false claim actually submitted to the government. The court dismissed the radiation-services claims for failure to state a claim and granted summary judgment on the chemotherapy claims due to lack of evidence.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decisions de novo. The appellate court held that the plaintiff failed to establish that the alleged physician supervision requirements were material preconditions for Medicare payment, and that he did not present evidence of any specific false claims for chemotherapy services. The court also found that the conspiracy claim failed because there was no underlying FCA violation. Accordingly, the Sixth Circuit affirmed the district court’s dismissal and grant of summary judgment in favor of the defendants. View "United States ex rel. O'Laughlin v. Radiation Therapy Services" on Justia Law

The plaintiff, a mail clerk with sickle cell anemia, was employed by the United States Postal Service (USPS) and had a history of attendance issues, some of which were covered by the Family Medical Leave Act (FMLA). To avoid termination, he entered into a Last Chance Agreement (LCA) that limited unscheduled absences and specified that FMLA-approved absences would not count against him if properly documented. After several disputed absences, some of which the plaintiff claimed were FMLA-protected, USPS terminated his employment for violating the LCA.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of USPS on most of the plaintiff’s claims, finding that he failed to establish FMLA coverage for all but one disputed date and did not sufficiently notify USPS of a need for accommodations under the Rehabilitation Act. The court also held that the plaintiff’s FMLA medical certification, which estimated two days of intermittent leave per month, created a hard cap on his FMLA leave. The plaintiff’s claims regarding one date were settled, and his motion for reconsideration was denied.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court affirmed the district court’s decision regarding the December 26, 2018 absence and the Rehabilitation Act claim, finding no evidence of a request for accommodation. However, it reversed the district court’s holding that the FMLA medical certification imposed a strict monthly limit on unforeseeable intermittent leave, clarifying that such certifications provide only estimates, not hard caps. The court remanded for further proceedings to determine whether the plaintiff gave proper notice for FMLA leave on certain dates and vacated the district court’s summary judgment on FMLA interference and retaliation claims related to the LCA, pending resolution of factual disputes. View "Jackson v. Postal Service" on Justia Law

A closely held Kentucky corporation, operated by members of the Tarter family, experienced a transfer of shares from the third generation (David, Donald, and Joy) to their children in December 2012. Despite this transfer, the corporation failed to observe corporate formalities such as holding annual shareholder or board meetings, leaving the composition of the board unclear. This ambiguity became significant when three shareholders sought to sue a family member, Josh Tarter, for alleged misconduct during his tenure as president. The plaintiffs attempted to have the board authorize the corporation to sue, and, alternatively, brought a derivative action on behalf of the corporation.The United States District Court for the Eastern District of Kentucky initially dismissed the complaint, finding the plaintiffs lacked standing for direct claims and failed to make a demand or show futility for derivative claims. After the plaintiffs attempted to cure these defects by calling a special board meeting and authorizing the suit, the district court first allowed the claims to proceed, then later granted summary judgment to the defendants, holding that the board vote was invalid because the third-generation members had resigned by transferring their shares. Upon reconsideration, the court vacillated, at one point accepting a theory that Anna Lou was the sole board member, but ultimately reinstated summary judgment for the defendants, reasoning that the plaintiffs had not properly pleaded this theory.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. It held that under Kentucky law and the corporation’s bylaws, the third-generation board members did not effectively resign by merely transferring their shares, as resignation required written or oral notice. Therefore, the board remained as constituted before the share transfer, and the special meeting authorizing the direct suit was valid. The court vacated the district court’s judgment, allowing the direct suit by the corporation to proceed, but affirmed dismissal of the derivative claims where demand was made and refused. View "C-Ville Fabricating, Inc. v. Tarter" on Justia Law

A woman who entered the United States illegally as a child was later granted Deferred Action for Childhood Arrivals (DACA) status, which rendered her prior removal order unenforceable. She frequently visited a local Immigration and Customs Enforcement (ICE) office to post bond for detainees and was well known to the staff. During one such visit, ICE agents detained her without a warrant or probable cause, despite being aware of her DACA status. She was held for eight days and transferred between multiple locations before being released. While detained, she sought habeas relief, but her petition was denied as moot after her release.She subsequently filed suit in the United States District Court for the Western District of Kentucky against the ICE agents, alleging violations of her First, Fourth, and Fifth Amendment rights under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics. The district court initially dismissed her claims for lack of subject matter jurisdiction under 8 U.S.C. § 1252(g), but the United States Court of Appeals for the Sixth Circuit reversed, holding that DACA status rendered the removal order non-executable and outside the jurisdiction-stripping provision. The Sixth Circuit also dismissed her First Amendment claim based on Supreme Court precedent. On remand, the district court granted summary judgment to the defendants on the remaining Fourth and Fifth Amendment claims, finding they constituted new Bivens contexts and that alternative remedies existed.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court held that the plaintiff’s Fourth and Fifth Amendment claims arose in new Bivens contexts—specifically, immigration enforcement by ICE agents outside the home and outside the federal employment context. The court further found that alternative remedies, such as administrative complaint procedures under the Immigration and Nationality Act and habeas corpus, precluded the extension of Bivens. Thus, no implied damages remedy was available. View "Enriquez-Perdomo v. Newman" on Justia Law