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

Richard Whitman was convicted of murder and unlawful possession of a firearm in an Ohio state court. The case revolved around whether Whitman acted in self-defense when he shot and killed David Eadie during a physical altercation at his sister's home. Whitman requested a jury instruction on the "castle doctrine," which would have informed the jury that a person lawfully in their residence has no duty to retreat before using force in self-defense. The trial court denied this request, and Whitman was subsequently convicted and sentenced to 21 years to life in prison.Whitman appealed his conviction to the Ohio Court of Appeals, arguing that the trial court erred by failing to instruct the jury on the castle doctrine. The appeals court upheld his conviction, ruling that any error did not affect Whitman's substantial rights. Whitman then sought to appeal to the Ohio Supreme Court, arguing for the first time that the trial court's error violated his federal due process right to a complete defense. The Ohio Supreme Court denied discretionary review.Whitman then turned to federal court, petitioning for a writ of habeas corpus. He claimed that the state court's denial of the castle doctrine instruction violated his federal due process rights. The district court denied Whitman's petition, deeming the castle doctrine issue a state law question and not a due process violation. Whitman appealed this decision.The United States Court of Appeals for the Sixth Circuit affirmed the district court's judgment. The court found that Whitman had procedurally defaulted his claim because he did not properly argue the merits of his due process claim in state court and is now barred from further review there. The court also noted that Whitman did not argue that he could satisfy the cause and prejudice standard which might otherwise overcome the default. The court concluded that enforcing Whitman's procedural default was justified by the interests of preservation, judicial economy, and comity. View "Whitman v. Gray" on Justia Law

The case involves Dorian McMullen, who was found by police in a high-crime neighborhood, sitting in his car with his legs sticking out the open door. As police approached in an unmarked vehicle, they observed McMullen reaching for something on the car's floorboard, which they suspected to be a gun. McMullen exited his car and engaged in a brief conversation with the police, during which he allegedly admitted to having a gun and crack cocaine in his car. The police then searched the car, finding a loaded pistol and narcotics. McMullen was arrested and later charged with being a felon in possession of a firearm.McMullen moved to suppress the gun evidence, arguing that it was seized in violation of his Fourth Amendment rights. The district court denied the motion, finding that the police had reasonable suspicion to temporarily stop and question McMullen, based on factors such as the high-crime neighborhood, proximity to a gang member's car, and McMullen's reaching motion towards the car's floorboard. The court also found that the police lawfully frisked McMullen and searched his car due to officer-safety concerns. McMullen pleaded guilty and appealed the decision.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the police had a valid basis for initiating a Terry stop, considering the totality of the circumstances. The court also found that the police took reasonable protective measures during the stop, including searching McMullen's car, which did not violate his constitutional rights. The court rejected McMullen's argument that the gun in his car was not immediately accessible to him at the time of the search, stating that a weapon is not necessarily inaccessible just because it is temporarily behind a closed door. View "United States v. McMullen" on Justia Law

The case involves a dispute over a protective order issued by the district court, barring Visser and Associates, PLLC (“Visser”) from communicating with potential class members in a putative class action. The case originated from a claim by Wayside Church that Van Buren County had violated the federal Constitution’s Takings Clause by foreclosing on its property to satisfy a tax debt and then selling the property for a higher amount without refunding the difference. The case was revived in federal court following the Supreme Court's overruling of a previous decision that required such claims to be pursued in state court.The district court preliminarily approved a proposed class action settlement between the plaintiffs and defendant counties. Around the same time, Visser began sending solicitation letters to property owners who it thought might have takings claims against counties in the Western District of Michigan. The district court issued a show-cause order, finding that Visser’s solicitation letters did not cross the line from permissible solicitation to misleading, improper communication with potential class members. However, the court was not satisfied with Visser’s explanation for why it had sent solicitation letters to named plaintiffs who were already represented by class counsel.The United States Court of Appeals for the Sixth Circuit affirmed the district court's protective order. The court found that Visser had violated ethical rules by soliciting named plaintiffs and misleading the court. The court also found that Visser had continued to solicit potential class members after the district court had preliminarily approved the class settlement. The court concluded that Visser's conduct posed a serious threat to the fairness of the litigation process and the administration of justice generally. Therefore, the district court did not abuse its discretion in issuing the protective order. View "Wayside Church v. Van Buren County" on Justia Law

The case involves Dr. John Stanton, who served as the medical director for a pain clinic in Tennessee. The federal government alleged that the clinic operated as a pill mill, and charged Dr. Stanton with conspiring to violate federal drug laws. Despite numerous red flags indicating the clinic's operation as a pill mill, Dr. Stanton continued to sign off on state compliance reports and prescribe narcotics to patients who failed drug screens. The government indicted Dr. Stanton, along with the clinic's owner and two patient sponsors, for conspiring to distribute controlled substances without a legitimate medical purpose.The case was first heard in the United States District Court for the Eastern District of Kentucky, where Dr. Stanton was found guilty by a jury. At sentencing, the court concluded that Dr. Stanton had prescribed a converted drug weight of at least 21,524 kilograms, leading to a recommended minimum sentence of 188 months. The trial court, however, varied downward to 120 months.Upon appeal to the United States Court of Appeals for the Sixth Circuit, Dr. Stanton challenged the sufficiency of the evidence supporting the jury’s verdict and several rulings by the trial court. The appellate court affirmed the lower court's decision. The court found that there was sufficient evidence to support the jury's finding that Dr. Stanton knowingly agreed to help the clinic and its owner illegally distribute controlled substances. The court also found no abuse of discretion in the trial court's decisions, including the allowance of a new expert witness for the government, the instruction to the jury on deliberate ignorance, and the response to the jury’s questions about the jury instructions. The court also upheld the drug weight calculation at sentencing. View "United States v. Stanton" on Justia Law

Jeffrey Capen, a former employee of Saginaw County, Michigan, sued the county and Robert V. Belleman, the county's Controller and Chief Administrative Officer, under 42 U.S.C. § 1983. Capen claimed that his procedural due process rights under the Fourteenth Amendment were violated when he was scheduled for two fitness-for-duty evaluations. The evaluations were ordered after a co-worker reported that Capen had threatened to kill other employees. Capen was subsequently placed on paid administrative leave and later terminated for failing to participate in an "interactive process" meeting to identify potential reasonable accommodations for his work, as required by the Americans with Disabilities Act.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the defendants. The court concluded that Capen lacked a constitutionally protected interest, that he received the process he was due, and that Belleman was entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The appellate court found that Capen's ability to refuse his fitness-for-duty evaluations did not constitute a protected interest under the Due Process Clause. The court noted that while the evaluations were stressful and deeply personal for Capen, he failed to demonstrate that his constitutional rights were violated. The court also observed that compelling circumstances justified the county's decision to require the evaluations, given the reported threats of violence. View "Capen v. Saginaw County, Michigan" on Justia Law

The case involves Oakland Tactical Supply, LLC and five Michigan residents who sued Howell Township, Michigan, alleging that the township's zoning restrictions, which prevented Oakland Tactical from constructing and operating a commercial shooting range, violated the Second Amendment. The district court granted the township's motion for judgment on the pleadings, concluding that the zoning restrictions did not violate the Second Amendment. The plaintiffs appealed this decision.The district court's decision was made before the Supreme Court announced a new framework for deciding Second Amendment challenges in New York State Rifle & Pistol Ass'n, Inc. v. Bruen. The Court of Appeals for the Sixth Circuit remanded the case for reconsideration in light of Bruen, and the district court again granted judgment for the township.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that while the Second Amendment protects the right to engage in commercial firearms training as necessary to protect the right to effectively bear arms in case of confrontation, it does not extend to training in a particular location or at the extremely long distances Oakland Tactical seeks to provide. The court concluded that the plaintiffs' proposed conduct—commercial training in a particular location and long-distance commercial training—was not protected by the plain text of the Second Amendment. Therefore, the township's zoning restrictions did not violate the Second Amendment. View "Oakland Tactical Supply, LLC v. Howell Township" on Justia Law

A group of Ohio voters sought to amend the Ohio Constitution through a ballot initiative. To do so, they had to submit their proposed amendment, a summary of the amendment, and one thousand supporting signatures to the Ohio Attorney General, who then had to certify that the summary was a fair and truthful statement of the proposed amendment. The Attorney General, David Yost, declined to certify the plaintiffs' summary on at least six occasions. After the most recent denial, the plaintiffs sought review from the Supreme Court of Ohio, which declined to grant expedited review. The plaintiffs then filed a complaint in federal district court, alleging that the Attorney General's enforcement of the certification requirement violated their First and Fourteenth Amendment rights by creating an unconstitutional obstacle to their ballot access and their ability to advocate for their proposed amendment. The district court denied the plaintiffs' motion for preliminary injunctive relief.On appeal, the United States Court of Appeals for the Sixth Circuit reversed the district court's decision. The appellate court found that the plaintiffs had standing to bring their claims and were not barred by sovereign immunity. The court also determined that the certification requirement imposed a severe burden on the plaintiffs' core political speech, and that the state had not shown that the requirement was narrowly tailored to its interests. The court therefore concluded that the plaintiffs were likely to succeed on the merits of their First Amendment claim. The court also found that the remaining factors for granting a preliminary injunction weighed in the plaintiffs' favor. The court therefore granted the plaintiffs' motion for preliminary injunctive relief, enjoining the Attorney General from enforcing the certification requirement against the plaintiffs. View "Brown v. Yost" on Justia Law

The case revolves around Roy Christopher West, who is serving a life sentence without parole for a conviction that the district judge has attributed to a sentencing error. West was indicted in 2010 on a charge of conspiracy to use interstate commerce facilities in the commission of murder for hire. He was tried twice, and during the second trial, he was convicted and sentenced to life imprisonment without parole. However, the indictment did not include any allegation that personal injury or death resulted from the conspiracy, and the jury was not instructed that death was an element of West's offense. The district court sentenced West under the federal murder-for-hire statute, which imposes a life sentence in cases where "death results." The court concluded that sentencing West to life imprisonment under these circumstances violated West's constitutional rights.West initially moved to vacate his sentence under 28 U.S.C. § 2255, arguing that his trial counsel was ineffective for failing to investigate a causation defense. The district court denied that motion. West then moved for compassionate release, arguing that his unconstitutionally imposed life sentence, combined with his rehabilitation while incarcerated, created an extraordinary and compelling circumstance that warranted a sentence reduction. The district court agreed and reduced his sentence to time served. However, the Government appealed, and the appellate court reversed, holding that compassionate release could not be used as a vehicle for second or successive § 2255 motions.West then sought relief from judgment under Federal Rule of Civil Procedure 60(b). The district court construed West's motion as a second or successive § 2255 motion and transferred it. West opposed the transfer and asked the appellate court to remand to the district court for a ruling on the merits of his Rule 60(b) motion. The appellate court vacated the district court's order construing West's motion as a second or successive § 2255 motion and remanded the motion to the district court to consider under Rule 60(b). View "In re: West" on Justia Law

The case revolves around Yvonne Craddock, an African American woman who was terminated from her employment at FedEx Corporate Services following a workplace altercation. Craddock alleged that her termination was racially motivated, in violation of Title VII of the Civil Rights Act of 1964. The case was presented to a jury, which concluded that FedEx's reason for termination was pretextual, but that Craddock had failed to demonstrate that FedEx intentionally discriminated against her because of her race. Craddock appealed, arguing that the district court had made several errors, including forcing her to bifurcate the liability and damages portions of her trial and excluding testimony and evidence pertaining to events post-termination.The district court had granted FedEx’s motion to dismiss Craddock’s libel claim, Family Medical Leave Act claim, 42 U.S.C. § 1981 claim, and spoliation claim, but denied dismissal of her Title VII claims. After discovery, the court granted FedEx’s motion for summary judgment on Craddock’s Title VII claims. The case was then taken to the United States Court of Appeals for the Sixth Circuit.The Court of Appeals held that the district court did not abuse its discretion regarding the claims raised by Craddock, and affirmed the jury’s verdict. The court found that the district court's decision to bifurcate the trial was not an abuse of discretion, and that the court's exclusion of testimony and exhibits postdating the termination was not erroneous. The court also found no error in the district court's trial rulings and case management decisions, and concluded that the jury verdict form was not plainly erroneous. The court further held that the cumulative effect of the alleged errors did not deprive Craddock of a trial consistent with constitutional guarantees of due process. View "Craddock v. FedEx Corporate Services, Inc." on Justia Law

An inmate, Timothy Finley, who suffers from severe psychiatric disorders, was placed in a heavily restrictive cell in administrative segregation for approximately three months by prison officials. Finley brought a case against the deputy wardens, Erica Huss and Sarah Schroeder, alleging violations of the Eighth Amendment and his right to procedural due process, as well as disability-discrimination claims under the Americans with Disabilities Act and the Rehabilitation Act.The district court granted summary judgment to Huss and Schroeder on all claims. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the lower court's decision on Finley’s procedural due process and statutory discrimination claims. However, the court reversed the lower court's decision on Finley’s Eighth Amendment claim, finding that he presented sufficient evidence to find that the deputy wardens violated his clearly established rights. The court remanded the case for further proceedings on the Eighth Amendment claim. View "Finley v. Huss" on Justia Law