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

In the early months of the COVID-19 pandemic, Ohio ordered the closure of "non-essential businesses." A group of dance-studio owners filed a lawsuit in federal court, alleging that various state and local officials had violated their constitutional rights by issuing these orders. The district court dismissed the complaint for failure to state a claim, and the United States Court of Appeals for the Sixth Circuit affirmed this dismissal on August 22, 2022. The appellate court held that the plaintiffs lacked standing against all defendants except former Ohio Director of Public Health Amy Acton and that the plaintiffs' substantive-due-process and equal-protection claims failed under rational-basis review. The court also affirmed the district court's rejection of the plaintiffs' takings claim.After the appellate court affirmed the dismissal, the district court issued a sanctions order against the plaintiffs' attorneys, Thomas B. Renz and Robert J. Gargasz, for their extensive legal failings throughout the case. The attorneys appealed the sanctions order. The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision to impose sanctions. The appellate court agreed that the attorneys had violated Rule 11 by presenting a complaint that was haphazard, incomprehensible, and littered with factual and legal errors. The court also upheld the imposition of sanctions under 28 U.S.C. § 1927, finding that the attorneys had unreasonably and vexatiously multiplied the proceedings with frivolous claims.The appellate court concluded that the district court did not abuse its discretion in granting sanctions and awarding attorney's fees and costs. The court emphasized that the attorneys' conduct fell short of the obligations owed by members of the bar and that the extreme sanction of attorney's fees was warranted given the egregious nature of their legal failings. The appellate court affirmed the district court's holding that the attorneys violated Rule 11 and section 1927 and upheld the grant of attorney's fees and costs. View "Bojicic v. DeWine" on Justia Law

In the 1950s, Goodrich Corporation built a vinyl-manufacturing complex in Calvert City, Kentucky, and used unlined ponds for hazardous waste disposal. In 1988, the EPA declared the site a Superfund site. Goodrich sold the complex to Westlake Vinyls, Inc. in the 1990s, agreeing to cover future cleanup costs. In 2000, PolyOne Corporation (now Avient Corporation) assumed Goodrich’s responsibilities. Disputes arose over cleanup costs, leading to a 2007 settlement agreement that included arbitration provisions for future cost allocations.The United States District Court for the Western District of Kentucky previously reviewed the case. Avient had twice sought arbitration under the agreement, first in 2010 and again in 2017. In 2018, Avient challenged the arbitration provisions' validity, but the district court held that Avient had waived this argument by initiating arbitration. The court enforced the arbitration award, and Avient did not challenge this decision. In 2022, Westlake demanded arbitration, and Avient again claimed the arbitration provisions were invalid. The district court granted summary judgment to Westlake, holding that Avient’s challenge was waived and barred by res judicata and judicial estoppel.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s judgment but on different grounds. The court held that the settlement agreement’s provision for de novo judicial review of arbitration awards was invalid under the Federal Arbitration Act, as established in Hall Street Associates, L.L.C. v. Mattel, Inc. However, the court found that this invalid provision could be severed from the agreement without affecting the economic and legal substance of the transactions contemplated by the parties. Therefore, the arbitration provisions remained valid and enforceable. The court affirmed the district court’s judgment. View "Avient Corp. v. Westlake Vinyls, Inc." on Justia Law

The Grand Traverse Band of Ottawa and Chippewa Indians and its employee welfare plan (the Plan) alleged that Blue Cross Blue Shield of Michigan (Blue Cross) breached fiduciary duties under ERISA and related duties under Michigan state law. The Tribe claimed that Blue Cross submitted false claims, causing the Tribe to overpay for hospital services. The Tribe also alleged violations of the Michigan Health Care False Claims Act (HCFCA) and sought to amend its complaint to include additional facts.The United States District Court for the Eastern District of Michigan dismissed the Tribe’s ERISA and common-law fiduciary duty claims as time-barred, granted summary judgment to Blue Cross on the HCFCA claim, and denied the Tribe’s motion for leave to amend its complaint a second time. The court found that the Tribe had actual knowledge in 2009 that it was not receiving Medicare-Like Rates (MLR) and thus the claims were time-barred. The court also concluded that Blue Cross was not directly governed by the MLR regulations, and therefore, the Tribe could not prove a violation of the HCFCA based on Blue Cross’s failure to apply MLR.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decisions. The appellate court agreed that the Tribe’s fiduciary duty claims were time-barred because the Tribe knew in 2009 that it was not receiving MLR. The court also upheld the summary judgment on the HCFCA claim, finding that the MLR regulations did not apply to Blue Cross. Additionally, the court found no error in the district court’s denial of the Tribe’s motion for leave to amend its complaint, as the proposed amendments would not have cured the deficiencies in the ERISA claim. View "Grand Traverse Band of Ottawa & Chippewa Indians v. Blue Cross Blue Shield of Michigan" on Justia Law

Devante Glenn was accused of selling drugs that led to the overdose death of Renee Ducatman. He was convicted on two counts of distributing carfentanil and one count of using a telecommunications device to facilitate the transaction. Ducatman had multiple interactions with Glenn and others through text messages and phone calls, seeking drugs. On the night of her death, she and Glenn exchanged messages and met, after which she overdosed on carfentanil.The United States District Court for the Northern District of Ohio conducted the trial. The jury convicted Glenn on all charges, and the court sentenced him to 240 months of imprisonment on one count and 48 months on the other counts, to be served concurrently. Glenn appealed, arguing insufficient evidence and improper expert testimony by Agent Orlando Almonte, who interpreted text messages between Glenn and Ducatman.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the district court erred in allowing Agent Almonte to testify as an expert on the meaning of common words and phrases in the text messages, as the jury was capable of interpreting them without expert assistance. The court determined that this error was not harmless, as the text messages were a significant part of the evidence against Glenn. Consequently, the court vacated Glenn’s conviction and remanded the case for further proceedings, allowing for a retrial without the improper expert testimony. View "United States v. Glenn" on Justia Law

Monica Gray, a long-time employee of State Farm, assisted a colleague, Sonya Mauter, in securing an ADA accommodation. Mauter's supervisor, Joe Kyle, opposed the accommodation and later reported Gray for timecard falsification. State Farm investigated and terminated Gray. Gray sued for retaliation under the ADA and Ohio law, alleging that Kyle targeted her due to her assistance to Mauter.The United States District Court for the Southern District of Ohio granted summary judgment to State Farm, concluding that the company had an honest belief that Gray engaged in misconduct, thus negating her retaliation claim. Gray appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court found that Gray presented sufficient evidence to establish a prima facie case of retaliation, including her protected activity, State Farm's knowledge of it, and a causal connection between her activity and termination. The court also determined that Gray raised a genuine dispute over whether State Farm's stated reason for her termination was pretextual, particularly given the differential treatment between Gray and another employee, Diane Parker, who had similar timekeeping discrepancies but was not reported.The Sixth Circuit held that Gray could proceed on a theory of vicarious liability, as Kyle's alleged bias and selective reporting could have influenced State Farm's decision to terminate her. The court reversed the district court's grant of summary judgment and remanded the case for further proceedings. View "Gray v. State Farm Mutual Auto Insurance Co." on Justia Law

Davariol Marquavis Taylor, an incarcerated individual, sued several members of the correctional staff at Marquette Branch Prison under 42 U.S.C. § 1983, alleging constitutional violations. Taylor claimed that a nurse administered incorrect medication, resulting in another inmate's overdose and death. He also alleged that a doctor sexually assaulted him and punched him when he resisted. Taylor sought to proceed in forma pauperis, which allows a litigant to avoid paying filing fees upfront due to financial constraints.The United States District Court for the Western District of Michigan denied Taylor's motion to proceed in forma pauperis, citing the Prison Litigation Reform Act’s (PLRA) “three-strikes” rule, which prevents incarcerated individuals from proceeding in forma pauperis if they have had three or more prior cases dismissed as frivolous, malicious, or failing to state a claim. The district court identified four previous cases as strikes against Taylor and dismissed his suit when he did not pay the filing fee. Taylor appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that Taylor had only two valid PLRA strikes, not three. The court determined that the district court's original order incorrectly counted two cases, Adler and Stump, as strikes. The court clarified that dismissals based on Eleventh Amendment immunity or improper filing under § 1983 do not count as strikes unless all claims in the complaint are dismissed for being frivolous, malicious, or failing to state a claim. Consequently, the Sixth Circuit vacated the district court's judgment and remanded the case for further proceedings consistent with its opinion. View "Taylor v. Stevens" on Justia Law

Mark Hartman was indicted for three counts of rape in Montgomery County, Ohio, following a late-night encounter. After a bench trial, he was convicted on all counts. Hartman filed a habeas petition under 28 U.S.C. § 2254, claiming ineffective assistance of counsel. He argued that his trial counsel improperly cross-examined witnesses and misled him into waiving his right to a jury trial. Ohio courts rejected his claims on the merits.The United States District Court for the Southern District of Ohio granted Hartman relief on his cross-examination claim, finding that his counsel introduced evidence of force that the state had not proven, making the trial fundamentally unfair. However, the court denied relief on Hartman’s jury-waiver claim, holding that the strategy to advise a bench trial was sound and that Hartman failed to show prejudice.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court reversed the district court’s grant of habeas relief on the cross-examination claim, finding that the Ohio Court of Appeals reasonably determined that trial counsel pursued a valid impeachment strategy during cross-examination. The court noted that the strategy aimed to reveal inconsistencies in the victim’s testimony, which is a common and reasonable trial tactic.Regarding the jury-waiver claim, the Sixth Circuit affirmed the district court’s denial of relief. The court held that the Ohio Court of Appeals reasonably concluded that trial counsel’s advice to waive a jury trial was within the wide range of reasonable professional conduct. The court found that counsel’s advice, despite some factual inaccuracies, did not render the waiver unknowing or unintelligent.In conclusion, the Sixth Circuit reversed the district court’s grant of a conditional habeas writ on the cross-examination claim, affirmed the denial of the jury-waiver claim, and remanded with instructions to deny Hartman’s petition for a writ of habeas corpus. View "Hartman v. Yost" on Justia Law

Anthony McClendon, a Michigan prisoner, was recommended by prison officials to participate in a sex-offender program due to his past conviction for criminal sexual conduct. McClendon refused to participate in the program, leading to repeated denials of parole by the Michigan parole board. McClendon filed a lawsuit under 42 U.S.C. § 1983, claiming that the recommendation to complete the sex-offender program and the subsequent parole denials violated his due process rights under the Fourteenth Amendment.The United States District Court for the Eastern District of Michigan dismissed McClendon’s complaint. The court found that McClendon did not have a cognizable liberty interest in avoiding the sex-offender label or in obtaining parole under Michigan’s discretionary parole system. The court also noted that McClendon’s past conviction for a sex offense negated any liberty interest in avoiding the requirement to complete a sex-offender program as a condition of parole.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo and affirmed the district court’s dismissal. The Sixth Circuit held that McClendon’s due process claim failed because he did not identify a cognizable liberty interest. The court determined that McClendon did not have a liberty interest in avoiding the sex-offender label or in obtaining parole under Michigan’s discretionary system. Additionally, the court found that McClendon’s past conviction for a sex offense meant he did not have a liberty interest in avoiding the requirement to complete a sex-offender program as a condition of parole. The court concluded that McClendon’s due process rights were not violated and affirmed the district court’s judgment. View "McClendon v. Washington" on Justia Law

Dawn Hayes was employed by Clariant Plastics & Coatings USA, Inc. for 25 years as a warehouse logistics clerk. In 2018, she was terminated as part of a workforce reduction program. Hayes contended that her termination was due to gender and age discrimination, and she also alleged unequal pay and a hostile work environment. She filed a lawsuit in federal court asserting these claims.The United States District Court for the Western District of Michigan granted summary judgment in favor of Clariant on all claims. The court found that Hayes did not establish a prima facie case of age discrimination and that her hostile work environment claim was time-barred and not administratively exhausted. The court also dismissed her state-law claims without prejudice.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court that Clariant was entitled to summary judgment on the age discrimination and hostile work environment claims. However, the court found that Hayes had presented a genuine issue of material fact on her gender discrimination and unequal pay claims. The court noted that Hayes had superior qualifications compared to a similarly situated male employee who was retained, and there was evidence of a discriminatory atmosphere at Clariant.The Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings on the gender discrimination and equal pay claims. The court also instructed the district court to reconsider its decision to dismiss the state-law claims in light of the reinstated federal claims. View "Hayes v. Clariant Plastics & Coatings USA, Inc." on Justia Law

Officer Jeff Smith, the oldest and longest-tenured police officer in the City of Union, Ohio, was terminated after allegedly violating several police department policies over a two-day period. An arbitrator later ordered his reinstatement, finding the termination to be an overreaction to minor and excusable mistakes. However, the City delayed his return for two months, requiring a fitness-for-duty examination and acting slowly once he passed it. During this delay, a younger officer was promoted, and raises were secured for all officers except Smith.Smith sued the City under the Age Discrimination in Employment Act (ADEA) and its Ohio counterpart, alleging age-based termination and retaliatory delay in his return for filing a charge with the Equal Employment Opportunity Commission (EEOC). The United States District Court for the Southern District of Ohio granted summary judgment to the City on both claims, leading Smith to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that a jury could view the facts and agree with Smith, particularly given the arbitrator's decision and a comment by the police chief about "younger officers." The court held that Smith presented enough circumstantial evidence to raise a triable question of whether the City terminated him due to his age. Additionally, the court found that the City's delay in reinstating Smith, which caused him to miss a promotion and a raise, could be seen as retaliatory.The Sixth Circuit reversed the district court's grant of summary judgment for the City and remanded the case for further proceedings, allowing Smith's claims of age discrimination and retaliation to proceed. View "Smith v. City of Union" on Justia Law