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

Eskender Getachew, a medical doctor in Columbus, Ohio, operated a clinic treating patients with opioid addiction. The government alleged that Dr. Getachew unlawfully prescribed controlled substances, particularly Subutex, at rates far exceeding medical norms, often without verifying patients’ claimed allergies to naloxone. Evidence at trial included testimony from an undercover officer, clinic staff, and an expert who identified repeated deviations from accepted medical practice, such as prescribing drugs without documented need and ignoring signs of drug diversion. The jury found Dr. Getachew guilty on eleven counts of unlawful distribution of controlled substances and not guilty on four counts.The United States District Court for the Southern District of Ohio presided over the trial. After conviction, Dr. Getachew was sentenced to concurrent six-month terms and three years of supervised release. He moved for a new trial, arguing ineffective assistance of counsel during plea negotiations and requested an evidentiary hearing, which the district court denied. Dr. Getachew appealed, challenging the sufficiency of the evidence, the deliberate-ignorance jury instruction, the content of that instruction, his absence at the return of the verdict, and the denial of an evidentiary hearing.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the evidence was sufficient to support the jury’s finding that Dr. Getachew knowingly issued unauthorized prescriptions. It found no plain error in the deliberate-ignorance instruction or its content. The court determined that Dr. Getachew’s absence at the verdict’s return did not affect his substantial rights and that the district court did not abuse its discretion in denying an evidentiary hearing on the new trial motion. The Sixth Circuit affirmed the district court’s judgment. View "United States v. Getachew" on Justia Law

Benjamin Carpenter was accused of providing translation and related services to ISIS, a designated foreign terrorist organization. He founded Ahlud-Tawhid Publications (ATP), which translated and published ISIS propaganda in multiple languages. Carpenter personally translated ISIS materials into English, wrote original content, and managed an ATP group on Telegram, where he coordinated translation projects. An undercover FBI agent, posing as an ISIS affiliate, joined the group and interacted with Carpenter, who recommended and facilitated the translation of ISIS propaganda videos at the agent’s request. Carpenter was arrested before completing a second translation assignment.The United States District Court for the Eastern District of Tennessee charged Carpenter with attempting to provide material support to a foreign terrorist organization under 18 U.S.C. § 2339B. After a five-day trial, a jury convicted him, and the district court sentenced him to 240 months in prison. Carpenter appealed, challenging the statute’s application to his conduct, evidentiary rulings, a protective order allowing an FBI agent to use a pseudonym, jury instructions, and the reasonableness of his sentence.The United States Court of Appeals for the Sixth Circuit reviewed Carpenter’s arguments and affirmed the district court’s judgment. The court held that translation services constitute “material support” as a “service” under the statute, consistent with Supreme Court precedent. The court found no abuse of discretion in the district court’s evidentiary rulings, including the admission of evidence related to Carpenter’s involvement with ATP and ISIS, the use of a pseudonym for the FBI agent, and the denial of Carpenter’s proposed jury instructions. The court also upheld the application of the terrorism sentencing enhancement and found the sentence both procedurally and substantively reasonable. The conviction and sentence were affirmed. View "United States v. Carpenter" on Justia Law

A nonprofit organization in Detroit, which provides educational and family services to at-risk youth, employed the plaintiff as a full-time case manager after she had previously worked as an independent contractor. The plaintiff’s responsibilities included monitoring students and managing case files, a task that required onsite work due to funding and audit requirements from a key county contract. After a building flood, the plaintiff raised health concerns about mold exposure and requested to work remotely, providing doctor’s notes that did not explicitly require remote work. The employer accommodated her request temporarily by shifting her to part-time remote work, but emphasized that onsite file management was essential. The plaintiff later returned to full-time onsite work. Over the following year, she filed several complaints with state agencies regarding workplace safety, pay, and reimbursement issues. During the COVID-19 pandemic, the organization faced financial difficulties, leading to a restructuring that offered the plaintiff a choice between an independent contractor role with reduced hours and benefits or a severance package. She declined both, ending her employment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the employer on all claims, finding insufficient evidence to support the plaintiff’s allegations of discrimination, retaliation, failure to accommodate, and wrongful termination. The court determined that the plaintiff could not perform essential job functions remotely and that the employer’s actions were based on legitimate business reasons.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the plaintiff failed to present evidence of a hostile work environment, disability-based discrimination, or retaliation under federal and state law. The court also found that the employer’s restructuring and accommodation decisions were not pretextual and that the plaintiff’s wrongful termination claim was inadequately developed and unsupported by the record. View "Kellar v. The Yunion, Inc." on Justia Law

Donald Roberts and Gun Owners of America challenged the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) after the agency issued a 2020 advisory instructing gun sellers not to accept Michigan concealed-pistol licenses as substitutes for the federally required National Instant Criminal Background Check System (NICS) check. Roberts was denied a gun purchase when he presented his Michigan license, prompting the lawsuit. The plaintiffs sought an injunction against enforcement of the advisory and a declaration that the ATF had exceeded its authority under the Administrative Procedure Act.The United States District Court for the Eastern District of Michigan initially granted summary judgment to the ATF on the merits. On appeal, the United States Court of Appeals for the Sixth Circuit vacated that order and remanded for further consideration of state law requirements. On remand, the district court dismissed the complaint for lack of standing, leading to another appeal.After the district court’s dismissal, the ATF issued a new advisory in May 2025, following a presidential executive order, which recognized Michigan licenses as valid alternatives to NICS checks and superseded the 2020 advisory. The United States Court of Appeals for the Sixth Circuit determined that these developments rendered the case moot, as the challenged policy was no longer in effect and the plaintiffs sought only prospective relief. The court found that neither the voluntary cessation nor the capable-of-repetition exceptions to mootness applied. Accordingly, the Sixth Circuit vacated the district court’s dismissal for lack of standing and remanded with instructions to dismiss the case as moot. View "Gun Owners of America, Inc. v. Dep't of Justice" on Justia Law

Over several months, the defendant participated in four carjackings targeting Lyft drivers in Detroit. In each incident, two assailants, including the defendant, brandished firearms, demanded money and property, and forced the victims to remove their clothing before fleeing in the stolen vehicles. One victim was pistol-whipped and sustained bodily injury. Extensive evidence, including phone records, cell site data, and identification by a victim, linked the defendant to each carjacking. A search of his residence uncovered multiple firearms and stolen vehicles. The defendant pleaded guilty to four counts of carjacking, aiding and abetting, admitting involvement but attempting to minimize his role in some attacks.The United States District Court for the Eastern District of Michigan prepared a presentence report recommending several offense level enhancements under the Sentencing Guidelines, including increases for brandishing and using firearms and for causing bodily injury. The defendant objected, arguing for a mitigating role reduction based on his claimed minor participation. The district court rejected his arguments, found by a preponderance of the evidence that he was a principal in each carjacking, and applied all recommended enhancements. The court imposed an above-Guidelines sentence of 180 months, citing the severity and humiliating nature of the crimes, the defendant’s prior criminal history, and his lack of respect for the law.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the procedural and substantive reasonableness of the sentence. The court held that the district court did not clearly err in its factual findings or in applying the offense level enhancements, nor did it plainly err in denying a mitigating role reduction or in considering the defendant’s age and rehabilitation potential. The appellate court found the upward variance substantively reasonable, given the egregious nature of the offenses and the impact on the victims. The sentence was affirmed. View "United States v. Haile" on Justia Law

After the death of Marjorie Johnson in 2020, her daughter, Rita Johnson, was appointed as executrix of her estate by the Wayne County, Michigan probate court. Rita initiated probate proceedings to determine whether certain assets belonged to the estate or to the Johnson Family Trust, which had a provision requiring arbitration of disputes. Amos C. Johnson, Marjorie’s son and trustee of the Trust, sought to compel arbitration in state court, but the request was denied. Subsequently, Amos and the Trust filed suit in the United States District Court for the Eastern District of Michigan, seeking to compel arbitration of the probate dispute under § 4 of the Federal Arbitration Act (FAA).The district court ordered the plaintiffs to show cause why the case should not be dismissed for lack of subject matter jurisdiction, citing the probate exception, the prior-exclusive-jurisdiction doctrine, and potential lack of diversity. The court ultimately dismissed the case, finding that the FAA does not provide an independent basis for federal question jurisdiction and that the probate proceedings were in rem, meaning the federal court would improperly interfere with property under the state probate court’s control.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s dismissal de novo. The Sixth Circuit held that federal courts may only compel arbitration under § 4 of the FAA if they would have jurisdiction over the underlying dispute. Because the probate proceedings were purely matters of state law and involved property already under the state court’s jurisdiction, the federal court lacked both federal question and diversity jurisdiction. The Sixth Circuit affirmed the district court’s dismissal, holding that the federal court did not have subject matter jurisdiction to compel arbitration of the state probate proceedings. View "Johnson v. Johnson" on Justia Law

The defendant was apprehended after two separate incidents in which he was found in possession of firearms and drugs. In the first incident, after a car accident, he attempted to dissuade the other driver from calling the police due to the presence of contraband in his vehicle, then fled but was quickly caught. In the second incident, a traffic stop led to the discovery of additional firearms, ammunition, and drugs. He was charged with two counts of possessing a firearm as a convicted felon and pleaded guilty.The United States District Court for the Eastern District of Kentucky calculated his base offense level under the Sentencing Guidelines as twenty-two, based in part on a prior Kentucky conviction for second-degree manslaughter, which the court classified as a “crime of violence.” The defendant did not object to this calculation at sentencing and was sentenced to 145 months in prison.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed whether Kentucky’s second-degree manslaughter qualifies as a “crime of violence” under the Sentencing Guidelines, applying plain error review because the issue was not raised below. The court held that the Kentucky statute’s “wantonness” mens rea is functionally equivalent to “recklessness” as defined in Borden v. United States, 593 U.S. 420 (2021), and does not meet the standard for a “crime of violence,” which requires purposeful or knowing conduct. The court found that the district court’s reliance on this conviction to enhance the sentence was plain error, affected the defendant’s substantial rights, and undermined the fairness of the proceedings. Accordingly, the Sixth Circuit vacated the sentence and remanded for resentencing. View "United States v. Tooley" on Justia Law

Andrew Maurice Randolph was convicted in Michigan state court of second-degree murder and weapons offenses after a shooting at his former girlfriend’s home resulted in the death of her mother. The prosecution’s case relied heavily on ammunition found in Randolph’s bags at his father’s house and a firearm discovered at his brother’s residence, which was identified as the murder weapon. Randolph’s trial counsel did not move to suppress this evidence, and Randolph argued that this failure, among other alleged deficiencies, constituted ineffective assistance of counsel.Following his conviction, Randolph appealed to the Michigan Court of Appeals, which rejected his ineffective assistance claim without explanation. The Supreme Court of Michigan reversed in part for unrelated reasons and remanded. On remand, the Michigan Court of Appeals affirmed the conviction, finding Randolph did not demonstrate a reasonable expectation of privacy in the searched belongings. The Supreme Court of Michigan denied leave to appeal. Randolph then sought federal habeas relief in the United States District Court for the Eastern District of Michigan, raising four ineffective assistance claims. The district court denied the petition, concluding that the suppression motion would have failed and that counsel’s other actions were either strategically reasonable or not prejudicial. The district court also denied a certificate of appealability (COA).On appeal, the United States Court of Appeals for the Sixth Circuit reviewed only the claim that trial counsel was ineffective for failing to move to suppress evidence obtained from the search of Randolph’s belongings, as this was the sole issue for which a COA was granted. The Sixth Circuit held that the state court’s factual findings and legal conclusions were reasonable under the Antiterrorism and Effective Death Penalty Act (AEDPA) and affirmed the district court’s denial of habeas relief. The court also denied Randolph’s request to expand the COA, holding that a merits panel lacks authority to do so. View "Randolph v. Macauley" on Justia Law

Two individuals were involved in a drug-trafficking operation distributing fentanyl and methamphetamine in the Lexington, Kentucky area. One supplied the drugs, which were pressed to resemble oxycodone pills, to the other, who then sold them to others. Both were apprehended after law enforcement used confidential informants and controlled buys. The supplier pleaded guilty to drug and firearm offenses, while the other pleaded guilty to conspiracy to distribute drugs.The United States District Court for the Eastern District of Kentucky sentenced the supplier to 228 months in prison and the other individual to 74 months, also imposing supervised release conditions. Both defendants challenged the procedural reasonableness of their sentences, specifically contesting the application of a sentencing enhancement under U.S.S.G. § 2D1.1(b)(13) for knowingly misrepresenting or marketing fentanyl as another substance. The second defendant also argued ineffective assistance of counsel, improper denial of a downward departure for reduced mental capacity, and an improper special condition of supervised release.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the district court properly applied the sentencing enhancement: the supplier knowingly misrepresented fentanyl as oxycodone, and the other knowingly marketed fentanyl as another substance, given the pills’ appearance and his knowledge of their contents. The court found no error in the district court’s reliance on a cooperating witness’s statement or in its findings regarding the defendants’ knowledge. The appellate court declined to address the ineffective assistance claim on direct appeal due to an insufficient record, found the denial of a downward departure unreviewable, and upheld the special condition of supervised release. The Sixth Circuit affirmed the district court’s judgments. View "United States v. Matthews" on Justia Law

A man walking along the shoulder of a Nashville interstate was approached by a state trooper, who intended to pat him down and offer a ride. During the encounter, the man produced a box cutter, failed to comply with repeated police commands, and a standoff ensued involving multiple officers from different agencies. After about thirty-five minutes, the man took two quick steps toward the officers, pulled an object from his pocket, and pointed it at them in a manner resembling a firearm. In response, nine officers fired approximately thirty-three shots, twelve of which struck and killed him. Notably, after the man had fallen to the ground and appeared incapacitated, one officer fired two additional shots.The decedent’s wife filed suit in the United States District Court for the Middle District of Tennessee against the involved cities and officers, alleging excessive force in violation of the Fourth Amendment. The officers moved to dismiss the complaint on the basis of qualified immunity. The district court denied the motions, finding that the complaint plausibly alleged a constitutional violation and that the right at issue was clearly established. The court also determined that video evidence did not blatantly contradict the plaintiff’s allegations regarding the officers’ conduct after the man was incapacitated.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the denial of qualified immunity de novo. The court held that eight of the nine officers were entitled to qualified immunity because their initial use of deadly force was objectively reasonable under the circumstances. However, the court found that the officer who fired two shots after the man was incapacitated was not entitled to qualified immunity at this stage, as the complaint plausibly alleged a violation of clearly established law prohibiting the use of force against a neutralized suspect. The court affirmed in part and reversed in part. View "Eastep v. City of Nashville" on Justia Law