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

In September 2020, Jesse Fairley was observed by law enforcement conducting hand-to-hand drug transactions in a convenience store parking lot. When officers approached and searched the vehicle Fairley had been using, they found crack cocaine, marijuana, cash, and two loaded firearms. Fairley was charged and convicted of possessing with intent to distribute crack cocaine, being a felon in possession of firearms, and possessing a firearm in furtherance of a drug trafficking crime. He received a thirty-year sentence and appealed his conviction.The United States District Court for the Northern District of Ohio denied Fairley's motions for acquittal, finding sufficient evidence for the jury to convict him. Fairley raised five issues on appeal, including the sufficiency of the evidence, the jury instructions on third-party guilt, the cumulative effect of evidentiary rulings, alleged improper communications with a defense witness, and improper closing remarks by the prosecution.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the lower court's decision. The court found that there was substantial evidence to support Fairley's convictions, including his proximity to the drugs and firearms, his observed drug transactions, and his evasive behavior. The court also determined that the jury instructions were not misleading, the evidentiary rulings were within the court's discretion, and there was no substantial interference with the witness's decision to testify. Additionally, the court found that the prosecution's closing remarks did not constitute plain error or prosecutorial misconduct. View "United States v. Fairley" on Justia Law

BlueCross BlueShield of Tennessee (BlueCross) is an insurer and fiduciary for an ERISA-governed group health insurance plan. A plan member in New Hampshire sought coverage for fertility treatments, which BlueCross denied as the plan did not cover such treatments. The Commissioner of the New Hampshire Insurance Department initiated an enforcement action against BlueCross, alleging that the denial violated New Hampshire law, which mandates coverage for fertility treatments. BlueCross sought to enjoin the state regulatory action, arguing it conflicted with its fiduciary duties under ERISA.The United States District Court for the Eastern District of Tennessee denied BlueCross's request for relief and granted summary judgment to the Commissioner. The court found that the Commissioner’s enforcement action was against BlueCross in its capacity as an insurer, not as a fiduciary, and thus was permissible under ERISA’s saving clause, which allows state insurance regulations to apply to insurers.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 Commissioner’s action was indeed against BlueCross as an insurer, aiming to enforce New Hampshire’s insurance laws. The court noted that ERISA’s saving clause permits such state actions and that BlueCross could not use its fiduciary duties under ERISA to evade state insurance regulations. The court also referenced the Supreme Court’s decision in UNUM Life Insurance Co. of America v. Ward, which established that state insurance regulations are not preempted by ERISA when applied to insurers. Thus, the Sixth Circuit concluded that ERISA did not shield BlueCross from the New Hampshire regulatory action. View "BlueCross BlueShield of Tennessee v. Nicolopoulos" on Justia Law

Debra Tucker applied for disability insurance benefits under Title II of the Social Security Act in 2018. After multiple denials at the administrative level, she appealed to the federal district court. In 2023, the district court reversed the final administrative decision of the Commissioner of Social Security, remanding Tucker’s claim for further administrative proceedings. The district court awarded Tucker’s attorney $7,500 in attorney’s fees under the Equal Access to Justice Act (EAJA), along with $402 in costs. Tucker’s attorney had a contingency-fee agreement for twenty-five percent of any past-due benefits awarded. In August 2024, an administrative law judge found Tucker disabled and granted her monthly disability benefits retroactive to February 2018, totaling $124,821.70 in past-due benefits.The district court granted in part and denied in part the attorney’s motion for $31,205.43 in fees under 42 U.S.C. § 406(b), awarding $17,400 instead. The court found the requested fee excessive, amounting to a windfall, and set an imputed hourly rate of $500. The attorney’s motion for reconsideration, reducing the fee request to $22,620, was denied. The attorney appealed, seeking the full $31,205.43.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court found that the district court properly started with the contingency-fee agreement and then tested it for reasonableness, considering the effective hourly rate and other factors. The district court did not misapply the law by comparing the effective hourly rate to the EAJA rate and the attorney’s ordinary rate. The appellate court affirmed the district court’s decision, concluding that it acted within its discretion in reducing the fee to avoid a windfall. View "Tucker v. Commissioner of Social Security" on Justia Law

Plaintiffs, current and former employees of DENSO International America, Inc., alleged that the company's 401(k) Plan overpaid for recordkeeping and administrative services, breaching the fiduciary duty of prudence under the Employee Retirement Income Security Act of 1974 (ERISA). They claimed that the Plan's fiduciaries failed to use their significant bargaining power to negotiate lower fees, resulting in excessive costs compared to similar plans.The United States District Court for the Eastern District of Michigan dismissed the plaintiffs' complaint, stating that it failed to provide the necessary "context specific" facts to support an ERISA overpayment-for-recordkeeping-services claim. The court found that the plaintiffs did not sufficiently detail the types and quality of services provided to the Plan compared to those provided to other plans.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 plaintiffs did not plausibly allege a breach of the duty of prudence because they failed to provide specific details about the services received by the Plan and how they compared to those received by the comparator plans. The court emphasized that a meaningful benchmark is necessary to evaluate whether the fees were excessive relative to the services rendered. The court also noted that general allegations about the fungibility of recordkeeping services and the bargaining power of mega plans were insufficient without specific context.The Sixth Circuit concluded that the plaintiffs' complaint did not meet the required pleading standards and affirmed the district court's dismissal of the case. View "England v. DENSO International America, Inc." on Justia Law

The case involves the Public Interest Legal Foundation (PILF) filing a two-count complaint against Jocelyn Benson, the Michigan Secretary of State, alleging non-compliance with the National Voter Registration Act of 1993 (NVRA). PILF claimed that Michigan failed to conduct proper maintenance of voter registration lists by not removing deceased registrants and did not allow inspection of public records related to voter rolls. PILF's requests for records and subsequent correspondence with the Secretary of State's office did not yield the desired information, leading to the lawsuit.The United States District Court for the Western District of Michigan granted summary judgment in favor of Secretary Benson. The court found that Michigan's efforts to maintain voter registration lists, including using state and federal death records and collaborating with the Electronic Registration Information Center (ERIC), constituted a reasonable effort under the NVRA. The court also found that PILF's claim regarding the failure to allow inspection of records was moot.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's summary judgment, agreeing that Michigan's program for removing deceased registrants was reasonable under the NVRA. The court noted that the NVRA requires a reasonable effort, not a perfect one, and that Michigan's multi-layered approach met this standard. The court also found that PILF lacked standing to assert its claim regarding the inspection of records, as it failed to demonstrate concrete downstream consequences from the alleged NVRA violation.In conclusion, the Sixth Circuit affirmed the district court's judgment, holding that Michigan's efforts to maintain accurate voter registration lists were reasonable and that PILF did not have standing to pursue its claim regarding the inspection of records. View "Public Interest Legal Foundation v. Benson" on Justia Law

Several hundred children in Benton Harbor, Michigan, suffered from elevated lead levels in their blood after drinking lead-contaminated water from the city’s public water system for three years. Plaintiffs, represented by their guardians, filed a lawsuit against various state and city officials, as well as two engineering firms, alleging that these parties failed to mitigate the lead-water crisis and misled the public about the dangers of the drinking water. The claims included substantive-due-process and state-created-danger claims under 42 U.S.C. § 1983, as well as state-law negligence claims.The U.S. District Court for the Western District of Michigan dismissed the complaint in full. The court found that the plaintiffs did not plausibly allege a violation of their constitutional rights and declined to exercise supplemental jurisdiction over the state-law claims. Plaintiffs appealed the dismissal of their federal claims against the city and state officials and the state-law claims against one of the engineering firms.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the dismissal of the claims against the state officials, finding that the plaintiffs did not plausibly allege that these officials acted with deliberate indifference. However, the court reversed the dismissal of the claims against the city officials and the City of Benton Harbor, finding that the plaintiffs plausibly alleged that these officials misled the public about the safety of the water, thereby causing the plaintiffs to drink contaminated water. The court also reversed the district court’s declination of supplemental jurisdiction over the state-law claims against the engineering firm and remanded the case for further proceedings. The court affirmed the district court’s denial of leave to amend the complaint. View "Mitchell v. City of Benton Harbor" on Justia Law

Larry Householder, former Speaker of the Ohio House of Representatives, and lobbyist Matthew Borges were convicted of conspiring to solicit and receive nearly $60 million in exchange for passing a billion-dollar bailout for a failing nuclear energy company, FirstEnergy Corp. Householder used the funds to support his bid for the speakership and to recruit candidates who would vote for him. Borges played a role in the conspiracy by attempting to disrupt a referendum campaign against the bailout legislation.The United States District Court for the Southern District of Ohio at Cincinnati found both Householder and Borges guilty after a 26-day trial. Householder was convicted of multiple counts, including public-official bribery, private-citizen bribery, and money laundering. Borges was also found guilty of participating in the conspiracy.The United States Court of Appeals for the Sixth Circuit reviewed the case and found no reversible error, affirming the convictions. The court held that the evidence was sufficient to support the jury's findings that Householder and Borges engaged in a quid pro quo arrangement with FirstEnergy. The court also upheld the jury instructions, finding them consistent with applicable law, and rejected Householder's claims of insufficient evidence, right to counsel violations, and judicial bias. Additionally, the court found that the district court did not abuse its discretion in its evidentiary rulings or in admitting the guilty pleas of co-conspirators.Householder's sentence of twenty years, the statutory maximum under RICO, was deemed procedurally and substantively reasonable. The court emphasized the magnitude and severity of Householder's offense, referring to it as the "biggest corruption case in Ohio's history." Borges's arguments regarding the sufficiency of the evidence and the district court's evidentiary rulings were also rejected, and his conviction was affirmed. View "United States v. Householder" on Justia Law

In 2014, federal law enforcement began investigating a website known as "Playpen," used to distribute child pornography. The Department of Justice obtained a warrant to reveal the IP addresses of Playpen users, leading to the identification of Eric Schuster in Ohio. A search of Schuster's residence uncovered multiple devices containing thousands of images and videos of child pornography. In May 2016, Schuster was indicted on three felony child pornography counts and detained pretrial.The case experienced significant delays in the district court. Initially, Schuster requested several continuances to review discovery and prepare motions. Over the next three years, Schuster's litigation conduct, including filing and withdrawing motions and requesting new counsel, contributed to the delays. In April 2019, Schuster's motions were fully briefed, but the district court took no action for twenty months. In December 2020, Schuster requested a status conference, and the court stayed proceedings for additional discovery. Another eighteen months passed without action on Schuster's motions.Schuster moved to dismiss his indictment in August 2022, arguing the delay violated his Sixth Amendment right to a speedy trial. The district court initially denied the motion but later reconsidered and dismissed the indictment with prejudice, finding the delay attributable to the court and the impact of incarceration during the COVID-19 pandemic.The United States Court of Appeals for the Sixth Circuit reviewed the case and applied the Barker v. Wingo factors. The court found that Schuster was responsible for much of the delay and failed to assert his right to a speedy trial in a timely and consistent manner. Additionally, Schuster did not demonstrate substantial prejudice resulting from the delay. The court concluded that Schuster's Sixth Amendment right was not violated and reversed the district court's decision, allowing the prosecution to proceed. View "United States v. Schuster" on Justia Law

In November 2021, a school shooting occurred at Oxford High School in Michigan, resulting in the deaths of four students and injuries to several others. This event had a profound impact on the local community, leading some families to transfer their children to other schools. Plaintiff C.S., a third-grade student at Robert Kerr Elementary School in Durand, Michigan, wore a hat depicting an AR-15-style rifle and the phrase "COME AND TAKE IT" to school during a "Hat Day" event. School officials, concerned about the potential for disruption given the recent shooting and the presence of transfer students from Oxford, asked C.S. to remove the hat.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the defendants, the school officials, concluding that their actions were justified under the circumstances. The court found that the school officials reasonably forecasted a substantial disruption due to the hat's imagery and message, particularly considering the recent trauma experienced by some students.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the school officials did not violate C.S.'s First Amendment rights by asking her to remove the hat. The court emphasized the unique context of the recent school shooting and the young age of the students, which justified the school officials' concerns about potential disruption. The court also found that the district court did not abuse its discretion in considering the defendants' untimely motion for summary judgment. View "C.S. v. McCrumb" on Justia Law

The plaintiff, Percy Brown, alleged that he was framed by University of Louisville Police Officer Jeffrey Jewell and several Louisville Metro Police Department officers for various crimes, including kidnapping, murder, rape, sodomy, and wanton endangerment, after he refused to cooperate in a check-forging investigation. Over more than ten years, the Commonwealth of Kentucky brought and dismissed numerous charges against Brown, resulting in his spending over seven years in prison. After the final indictment was dismissed, Brown filed a lawsuit.The United States District Court for the Western District of Kentucky dismissed Brown's malicious-prosecution claim related to the murder charge as barred by the statute of limitations. The court found that the claim accrued when the murder charge was dismissed on February 24, 2015, and thus was time-barred. The court also granted Jewell’s motion for judgment on the pleadings regarding Brown’s fabrication-of-evidence claim, finding it insufficiently pleaded.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of the malicious-prosecution claim, agreeing that it was time-barred. The court held that the murder charge was separable from the other charges against Brown, which were dismissed later, and thus the statute of limitations for the malicious-prosecution claim related to the murder charge began to run when that charge was dismissed. The court also found that the continuing-violation doctrine did not apply, as the last alleged unlawful act occurred more than a year before Brown filed his lawsuit. Consequently, the Sixth Circuit affirmed the district court's decision. View "Brown v. Louisville-Jefferson County Metro Government" on Justia Law