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

David Hieber, who led Oakland County’s Equalization Department for nearly twenty years, was terminated after an employee reported him for creating a hostile work environment. Hieber sued Oakland County and his supervisor, Kyle Jen, under 42 U.S.C. § 1983 for deprivation of pretermination and post-termination due process, political-affiliation retaliation, and age discrimination. He also brought state-law claims for defamation and age discrimination. Oakland County and Jen moved for summary judgment, which the district court granted.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of Oakland County and Jen on all claims. Hieber appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court reversed the district court’s grant of summary judgment to Oakland County and Jen, in his official capacity, on Hieber’s pretermination due-process claim, finding that there was a genuine dispute of material fact about whether Hieber received a meaningful opportunity to respond to the charges against him. The court affirmed the district court’s judgment on Hieber’s post-termination due-process claim, political-affiliation retaliation claim, age discrimination claims, and defamation claim. The court also affirmed the district court’s grant of qualified immunity to Jen in his individual capacity on the due-process claims.The main holding of the Sixth Circuit was that Hieber’s pretermination due-process rights may have been violated, warranting further proceedings on that claim. The court found that the investigatory interview and the pretermination hearing may not have provided Hieber with adequate notice of the charges and a meaningful opportunity to respond. The court remanded the case for further proceedings consistent with its opinion. View "Hieber v. Oakland County, Mich." on Justia Law

Amaury Villa participated in two significant burglaries in 2011, stealing $61 million worth of pharmaceuticals from an Eli Lilly warehouse in Connecticut and $1.5 million worth of cigarettes from a warehouse in Kentucky. He was indicted by federal grand juries in Florida, Connecticut, and Kentucky. Villa pled guilty in the Florida and Connecticut cases, receiving concurrent prison terms of 140 and 98 months, respectively. In January 2016, Kentucky prosecutor Joshua Judd emailed Villa’s attorney, Donald Meier, a proposed plea agreement that did not mention concurrent sentencing. Villa later pled guilty without a plea agreement and was sentenced to 77 months, to be served consecutively.Villa moved to set aside his Kentucky sentence under 28 U.S.C. § 2255 in January 2019, claiming ineffective assistance of counsel. He later sought to amend his motion to add a claim that Meier failed to inform him of a potential cooperation agreement. The district court initially denied the motion as untimely. On appeal, the Sixth Circuit remanded for an evidentiary hearing on the timeliness of the claim. The district court found the claim timely but denied it on the merits.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The court found that Judd’s January 21 email did not constitute a formal plea offer but was an invitation to negotiate. The court also found that Meier had informed Villa of the January 9 plea offer, which was discussed at Villa’s change-of-plea hearing. The court concluded that Meier’s performance was not deficient and that Villa himself impeded further negotiations by refusing to provide additional information about his co-conspirator. The district court’s judgment denying Villa’s motion to vacate, set aside, or correct his sentence was affirmed. View "Villa v. United States" on Justia Law

Sonya Kenette Brown, a City Council member in Albion, Michigan, was prosecuted for allegedly violating a City Charter provision that prohibits council members from directing the appointment or removal of city employees. Brown claimed that her political opponents on the City Council engaged in retaliatory prosecution and arrest, malicious prosecution, and conspiracy to violate her civil rights. She also challenged the constitutionality of the City Charter provision.The United States District Court for the Western District of Michigan dismissed Brown's claims of retaliatory prosecution and arrest, malicious prosecution, and conspiracy, finding that there was probable cause for her prosecution based on her Facebook messages. The court also granted summary judgment to the defendants on Brown's claim that the City Charter provision was unconstitutional.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal of Brown's claims, agreeing that there was probable cause for her prosecution. The court found that Brown's Facebook messages provided sufficient evidence to believe she had violated the City Charter by directing the removal of a city employee. The court also held that the City Charter provision was not unconstitutionally vague or overbroad, as it provided clear standards and did not prohibit a substantial amount of protected speech.The Sixth Circuit concluded that Brown's claims failed because she could not demonstrate an absence of probable cause, and the City Charter provision was constitutionally valid. The court affirmed the district court's judgment in favor of the defendants. View "Brown v. City of Albion, Mich." on Justia Law

Lathfield Investments, LLC, Lathfield Holdings, LLC, and Lathfield Partners, LLC (collectively, "Lathfield") own three commercial buildings in Lathrup Village, Michigan, rented to various commercial tenants. The City of Lathrup Village and its Downtown Development Authority (collectively, the "City") require landlords to obtain a rental license and list each tenant's name and principal business. Lathfield applied for a landlord rental license in July 2020 but did not list the required tenant information, leading to the denial of their application and their tenants' business license applications. Lathfield sued the City, alleging unlawful compulsion to apply for unnecessary licenses and make unnecessary property improvements, bringing eleven claims, nine against the City.The United States District Court for the Eastern District of Michigan granted summary judgment to the City on all nine claims. Lathfield appealed, arguing that the City improperly required site plan approval, violated due process and equal protection rights, and engaged in inverse condemnation, among other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The court held that Lathfield's request for declaratory relief regarding site plan approval was moot since the site plan process was already completed. The court also found that Lathfield was required to obtain a general business license under the City Code and that the City Code's tenant registration requirement applied to Lathfield. The court rejected Lathfield's due process claims, noting that the City’s adoption of the Michigan Building Code was a legislative act not subject to procedural due process requirements. The court also dismissed Lathfield's equal protection claim due to a lack of evidence of differential treatment and found no basis for the Contracts Clause claim under 42 U.S.C. § 1983. Lastly, the court concluded that Lathfield failed to establish an inverse condemnation claim or a civil conspiracy. View "Lathfield Investments, LLC v. City of Lathrup Village, Mich." on Justia Law

Federal law enforcement investigated crystal-methamphetamine trafficking in rural eastern Tennessee in July 2019, leading them to Derrick Mitchell in Knoxville. In October 2020, authorities executed a search warrant at Mitchell’s home, finding drugs, firearms, ammunition, and cash. Mitchell pleaded guilty to conspiring to distribute methamphetamine and to commit money laundering. He waived his right to appeal unless the district court imposed an above-Guidelines sentence. The district court accepted his plea and imposed a below-Guidelines sentence.The United States District Court for the Eastern District of Tennessee accepted Mitchell’s plea agreement, which included a stipulation that no other upward enhancements would apply apart from a two-level increase for money laundering. However, the probation office recommended additional enhancements, including one for possessing a firearm in connection with a drug-trafficking offense. Mitchell’s counsel did not initially object to the presentence report, and the district court adopted it in full. Later, Mitchell’s counsel raised the issue of the firearm enhancement, but the court explained that the stipulations in the plea agreement were not binding.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Mitchell’s appeal must be dismissed because he waived his right to appeal under the plea agreement, which was voluntarily accepted. The court found no plain error in the district court’s acceptance of Mitchell’s plea, as the court had adequately informed him of the consequences, and Mitchell understood the nature of his plea. The court also determined that the government did not breach the plea agreement, as it had not promised that only one enhancement would apply and had not objected to the probation office’s recommendation. The appeal was dismissed in accordance with the plea agreement’s appellate waiver provision. View "United States v. Mitchell" on Justia Law

Jeremy Mooney, a former deputy in the Pike County Sheriff’s Office, was convicted of two counts of depriving an inmate, Thomas Friend, of his civil rights under color of law, in violation of 18 U.S.C. § 242. The incidents occurred on November 17-18, 2019, when Mooney pepper sprayed and punched Friend multiple times while Friend was restrained in a chair. Surveillance footage captured these events. Mooney claimed his actions were in response to Friend spitting on him and that he was instructed by his supervisor to use pepper spray.The United States District Court for the Southern District of Ohio denied Mooney’s motion to dismiss the indictment, which argued that the government destroyed exculpatory video evidence in bad faith. The court found no bad faith or exculpatory value in the lost footage. At trial, the jury found Mooney guilty on both counts. The court also excluded evidence of Friend’s Hepatitis C, ruling it irrelevant and potentially prejudicial. Mooney was sentenced to 100 months in prison, with an enhancement for obstruction of justice based on allegedly false trial testimony.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed Mooney’s conviction, finding sufficient evidence that Mooney acted willfully to deprive Friend of his constitutional rights. The court also upheld the district court’s evidentiary rulings, including the exclusion of the Hepatitis C evidence and the admission of testimony from Deputy Jonathan Chandler about police training.However, the Sixth Circuit vacated Mooney’s sentence and remanded the case for further proceedings regarding the obstruction of justice enhancement. The court found that the district court failed to make specific findings necessary to establish perjury, as required for the enhancement. The case was sent back to the district court to either resentence Mooney or make the required factual findings. View "United States v. Mooney" on Justia Law

Police stopped Prince Irell Seuell in Van Buren County, Michigan, in November 2023, discovering drugs, a semiautomatic pistol, and an outstanding warrant. Seuell pleaded guilty to possessing a firearm as a felon, and the government dropped the drug distribution charge. The presentence report calculated a Guidelines range of 70 to 87 months, and the district court sentenced Seuell to 70 months.Seuell challenged his conviction and sentence. He argued that the felon-in-possession statute violated the Second Amendment as applied to him, but he waived this argument at sentencing. The district court offered to appoint new counsel to file a motion challenging the statute, but Seuell chose to proceed with sentencing without raising the motion. The court found this waiver binding.Seuell also contested the base offense level set by the presentence report, arguing that he did not know his pistol could carry a large capacity magazine. The United States Court of Appeals for the Sixth Circuit held that the relevant Guideline does not contain a state-of-mind requirement and applies whenever the firearm qualifies. The court noted that the Sentencing Commission knew how to add a state-of-mind requirement when it wished to do so and rejected Seuell's argument.Additionally, Seuell challenged the district court’s enhancement for using a firearm in connection with another offense. The Sixth Circuit found no clear error in the district court’s finding that Seuell committed another felony offense and connected his pistol to drug trafficking. The court noted that the drugs and drug paraphernalia were found in close proximity to the loaded pistol, supporting the enhancement.The United States Court of Appeals for the Sixth Circuit affirmed Seuell’s conviction and sentence. View "United States v. Seuell" on Justia Law

Jin Yin Zhou, a Chinese citizen, married a U.S. citizen in 1996 and entered the United States as a conditional permanent resident in 1997. However, she never lived with her husband and instead lived with her boyfriend in Kentucky, with whom she had three children. Zhou concealed these facts during her immigration proceedings, including when she applied for naturalization. Eventually, the United States Citizenship and Immigration Services discovered her marriage fraud, leading to her being placed in removal proceedings. The immigration judge sustained the charge of removability but granted her relief from removal under 8 U.S.C. § 1227(a)(1)(H), considering her long residence, stable employment, and the hardship her children would face if she were removed.The Department of Homeland Security appealed the immigration judge's decision to the Board of Immigration Appeals (BIA). Zhou's counsel failed to file a brief on her behalf, and the BIA reversed the immigration judge's decision, ordering Zhou's removal. Zhou filed an untimely motion to reopen her removal proceedings, requesting equitable tolling of the 90-day deadline due to ineffective assistance of counsel. The BIA denied the motion, stating that Zhou failed to demonstrate the requisite prejudice and due diligence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that it lacked jurisdiction to review the BIA's determination regarding the lack of prejudice, as this determination was dispositive of the appeal. Consequently, the court dismissed Zhou's petition for review. View "Zhou v. Bondi" on Justia Law

Several hair stylists filed a lawsuit against their employer, Lady Jane’s Haircuts for Men, alleging that they were underpaid due to being misclassified as independent contractors instead of employees. This misclassification, they argued, allowed the employer to avoid the Fair Labor Standards Act’s minimum-wage and overtime-pay requirements. The employer moved to dismiss the lawsuit, citing an arbitration agreement in the Independent Contractor Agreement, which required disputes to be resolved through the American Arbitration Association (AAA) under its Commercial Arbitration Rules.The United States District Court for the Eastern District of Michigan reviewed the case and found the arbitration agreement enforceable but severed the cost-shifting provision, which required the stylists to pay arbitration costs exceeding their yearly income. The court ruled that the arbitration would proceed under the less costly AAA employment rules and dismissed the lawsuit in favor of arbitration.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 severability clause in the contract allowed the court to remove the cost-shifting provision while enforcing the rest of the arbitration agreement. The court found that the term “provision” in the severability clause referred to individual clauses within the contract, not entire sections. The court also rejected the stylists’ arguments that the district court had impermissibly reformed the contract and that the arbitration agreement should be unenforceable for equitable reasons. The court concluded that the district court correctly severed the cost-shifting provision and enforced the arbitration agreement under the AAA’s employment rules. View "Gavin v. Lady Jane's Haircuts for Men" on Justia Law

Enbridge Energy owns and operates a pipeline that runs from Wisconsin, through Michigan, and into Canada, crossing the Straits of Mackinac under a 1953 easement with the State of Michigan. In 2020, Michigan Governor Gretchen Whitmer informed Enbridge that the State was revoking the easement, alleging that Enbridge had violated it by creating an unreasonable risk of an oil spill. Enbridge responded by filing a federal lawsuit against Governor Whitmer and the Director of the Michigan Department of Natural Resources, seeking declaratory and injunctive relief to prevent the State from interfering with the pipeline's operation.The United States District Court for the Western District of Michigan rejected the defendants' argument that Enbridge’s claims were barred by Eleventh Amendment sovereign immunity. The court held that Enbridge’s lawsuit fell within the Ex parte Young exception to sovereign immunity, which allows federal courts to hear cases seeking prospective relief against state officials for ongoing violations of federal law.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 Enbridge’s lawsuit was not barred by sovereign immunity because it sought prospective injunctive relief against state officials for alleged violations of federal law, fitting within the Ex parte Young doctrine. The court rejected the defendants' arguments that the suit was equivalent to a quiet title action or a request for specific performance of a state contract, finding that the relief sought would not divest the State of ownership or regulatory control over the land. Thus, the court concluded that Enbridge’s claims could proceed in federal court. View "Enbridge Energy, LP v. Whitmer" on Justia Law