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

During a late-night traffic stop, officers found two firearms in Andre Whitlow’s car. As Whitlow was a felon, it was illegal for him to possess the guns. At trial, a jury found him guilty of being a felon in possession. Whitlow appealed, challenging various aspects of the traffic stop and his conviction.The United States District Court for the Northern District of Ohio denied Whitlow’s motion to suppress the firearms found during the search. The court found that Officer Kazimer had probable cause to search the car based on the marijuana observed in the vehicle. After a two-day trial, the jury found Whitlow guilty, and the court sentenced him to 120 months in prison.The United States Court of Appeals for the Sixth Circuit reviewed the case. Whitlow argued that Officer Kazimer lacked probable cause to search his car, the evidence was insufficient to convict him, the district court erroneously admitted various pieces of evidence, allowed improper testimony, and that his sentence was procedurally unreasonable. The Sixth Circuit affirmed the lower court’s decision, holding that Officer Kazimer had probable cause to search the car based on the marijuana observed, and the evidence was sufficient to support the conviction. The court also found that the district court did not err in admitting the Instagram photographs and prior police interaction as evidence, nor in allowing the officer to identify himself as being from the Homicide Unit. Finally, the court upheld the procedural reasonableness of Whitlow’s sentence, including the two-level enhancement for possessing a stolen firearm. View "United States v. Whitlow" on Justia Law

Joseph Ebu, a lawful permanent resident, was involved in concurrent naturalization and removal proceedings. The United States Citizenship and Immigration Services (USCIS) delayed considering his naturalization application due to the pending removal proceedings. When the delay exceeded 120 days after his naturalization examination, Ebu sought judicial intervention to determine his naturalization application and declare him prima facie eligible for naturalization under 8 U.S.C. § 1447(b). The district court dismissed his complaint, citing a provision that prohibits the determination of a naturalization application while removal proceedings are pending, relying on the unpublished opinion in Rahman v. Napolitano.The United States District Court for the Eastern District of Kentucky dismissed Ebu’s complaint, agreeing with USCIS that removal proceedings take priority over naturalization applications. The court followed the precedent set in Rahman, which held that 8 U.S.C. § 1429 precludes district courts from considering naturalization applications under § 1447(b) while removal proceedings are pending.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s dismissal. The court held that § 1429’s prohibition on the Attorney General from considering naturalization applications during pending removal proceedings also applies to district courts. The court emphasized that Congress intended for removal proceedings to take priority over naturalization applications, regardless of the forum. The court also rejected Ebu’s request for a declaratory judgment on his prima facie eligibility for naturalization, stating that such a judgment would be an impermissible advisory opinion. The court concluded that the district court correctly dismissed Ebu’s complaint based on § 1429 without considering the merits of his naturalization application. View "Ebu v. Citizenship and Immigration Services" on Justia Law

EOG Resources, Inc. holds drilling rights to oil and gas beneath property owned by Lucky Land Management, LLC in Ohio. The dispute arose over whether EOG's drilling rights included the right to drill horizontally from Lucky Land's surface to adjacent properties. EOG sought a preliminary injunction to access the land, cut down trees, and start constructing drills. The district court granted the injunction, finding that EOG would likely succeed on the merits.The United States District Court for the Southern District of Ohio granted EOG's request for a preliminary injunction, allowing EOG to access the land and begin drilling operations. The court found that EOG was likely to succeed on the merits of its claim and that the balance of equities and public interest favored granting the injunction. Lucky Land Management appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and disagreed with the district court's findings. The appellate court held that Lucky Land had the better interpretation of oil-and-gas law, which generally does not allow a lessee to use the surface of one property to drill into neighboring lands without explicit permission. The court also found that EOG would not suffer irreparable harm if it had to wait for the litigation to proceed, as any potential losses could be compensated with monetary damages. The court emphasized that preliminary injunctions are meant to prevent irreparable injuries and preserve the court's ability to issue meaningful final relief, not to serve as shortcuts to the merits. Consequently, the Sixth Circuit reversed the district court's decision to grant the preliminary injunction. View "EOG Resources, Inc. v. Lucky Land Management, LLC" on Justia Law

Allen Walker pleaded guilty to conspiracy with intent to distribute and dispense controlled substances and was sentenced to 96 months in prison on August 20, 2015. He did not appeal, making the judgment final on September 3, 2015. Walker had until September 3, 2016, to file a habeas motion under 28 U.S.C. § 2255. In August 2016, Walker sent a letter to the district court requesting more time to file his motion and for the appointment of counsel, citing ineffective assistance of counsel. The district court denied his request on jurisdictional grounds but provided a form for filing a § 2255 motion. Walker filed his motion pro se on August 17, 2017, almost a year after the deadline.The United States District Court for the Middle District of Tennessee denied Walker's motion as untimely, despite the government not raising the statute of limitations defense. Walker appealed, and the case was remanded to determine if the government's failure to raise the defense constituted forfeiture or waiver. The district court concluded it was forfeiture and again denied Walker's motion as time-barred.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the government waived the statute of limitations defense by not raising it despite being aware of the timeliness issue. The court noted that the government had multiple opportunities to address the statute of limitations but chose to focus on the merits of Walker's claim instead. Consequently, the district court erred in considering the timeliness issue sua sponte. The Sixth Circuit reversed the district court's decision and remanded the case for further proceedings on the merits of Walker's § 2255 motion. View "Walker v. United States" on Justia Law

Patrick Reed was convicted of drug trafficking, drug possession, firearm possession, and evidence tampering. The police, with the help of confidential informants, conducted controlled drug purchases from Reed near a house on Larchmont Drive in Sandusky, Ohio. A search warrant for the house led to the discovery of firearms, ammunition, cash, drug paraphernalia, and drugs. Evidence linking Reed to the house was also found. During the trial, a detective testified about the investigation and the search, including information from a confidential informant about where Reed hid drugs. The trial court instructed the jury to consider the informant's tip only to explain the detective's actions, not for the truth of the matter asserted.Reed appealed, arguing that his Confrontation Clause rights were violated because the informant did not testify, preventing cross-examination. The Ohio Court of Appeals rejected this claim, stating that the trial court's instructions to the jury were sufficient. The Ohio Supreme Court declined to hear Reed's appeal. Reed then filed a habeas corpus petition in federal court, which was dismissed. The district court certified one question for review: whether the Ohio trial court properly admitted the detective's testimony about the informant's tip.The United States Court of Appeals for the Sixth Circuit reviewed the case under the Antiterrorism and Effective Death Penalty Act (AEDPA). The court held that the Confrontation Clause does not apply to non-hearsay statements, and the informant's tip was admitted for a non-hearsay purpose—to explain the detective's actions. The court found that the Ohio courts' decision was not contrary to or an unreasonable application of clearly established federal law. The court affirmed the district court's denial of Reed's habeas petition. View "Reed v. May" on Justia Law

Plaintiffs, Ohio voters and members of an initiative petition committee, sought to amend the Ohio Constitution through two ballot initiatives. The Ohio Attorney General, David Yost, rejected their proposed summaries eight times, preventing them from collecting signatures. Plaintiffs argued that this violated their First Amendment rights. The district court agreed, issuing a preliminary injunction ordering Yost to certify the summaries. However, the district court stayed the injunction pending appeal.The United States District Court for the Southern District of Ohio initially denied preliminary injunctive relief, but a panel of the Sixth Circuit reversed, finding that the fair-and-truthful review process likely violated Plaintiffs' First Amendment rights. The en banc Sixth Circuit later vacated this decision, deeming the case moot as the targeted election had passed. Plaintiffs then filed an amended complaint and sought a second preliminary injunction, which the district court granted, but stayed pending appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case and agreed with the district court that Plaintiffs' First Amendment rights were likely violated. The court found that the fair-and-truthful certification process allowed the Attorney General to exercise editorial control over the petition summaries, which constituted a severe burden on Plaintiffs' core political speech. The court also determined that the other stay factors did not favor Yost. Consequently, the Sixth Circuit granted Plaintiffs' motion to lift the stay, allowing them to proceed with their petition efforts. View "Brown v. Yost" on Justia Law

Randy Erickson, an inmate at Gogebic County Jail, Michigan, was involved in an incident with Deputy Sheriff Scott Voit. Erickson, who was serving a sentence for operating a vehicle while intoxicated, had an altercation with Voit after making a disrespectful comment. Voit responded by canceling Erickson's family visit, which led Erickson to act out by hitting and kicking the cell door. Voit then handcuffed Erickson and took him to a holding cell, where he threw Erickson to the ground and kneed him in the back. Erickson later sought medical attention for injuries including a fractured rib and back contusions.The United States District Court for the Western District of Michigan denied Voit's motion for summary judgment on qualified-immunity grounds, finding that a reasonable jury could conclude that Voit used excessive force maliciously and sadistically to cause harm. However, the court also found that there was no evidence to suggest that Voit deliberately disregarded Erickson's medical needs, as there was no indication that Voit knew of Erickson's injuries.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court that a reasonable jury could find that Voit used excessive force in violation of the Eighth Amendment, as the force used was disproportionate to the threat posed by Erickson, who was handcuffed and compliant. The court held that Voit was not entitled to qualified immunity on the excessive force claim because the law clearly established that malicious and sadistic use of force violated the Eighth Amendment.However, the Sixth Circuit disagreed with the district court regarding the claim of deliberate indifference to medical needs. The court found no evidence that Voit knew of Erickson's injuries or that Erickson requested medical care from Voit. Therefore, the court held that Voit did not act with deliberate indifference to Erickson's medical needs.The Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. View "Erickson v. Gogebic County" on Justia Law

US Framing International LLC entered into a subcontract with Continental Building Company for framing services on two student-housing projects. Disputes arose, leading US Framing to leave the Knoxville project. Continental then filed an insurance claim alleging US Framing's breach of the subcontract. US Framing sued Continental and its officers, claiming insurance fraud under Tennessee law. The district court dismissed the case, stating US Framing failed to plead any injury directly caused by the alleged fraudulent insurance claim.The United States District Court for the Eastern District of Tennessee initially reviewed the case. The court granted Continental's motion to dismiss, concluding that US Framing did not demonstrate any direct injury resulting from Continental's insurance claim. US Framing then appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that US Framing did not plausibly allege any economic damages directly resulting from Continental's alleged insurance fraud. The court also determined that US Framing could not recover attorney's fees or statutory penalties, as it did not establish itself as a prevailing party entitled to such relief. The court's decision was based on the interpretation of Tennessee law, which requires a direct causal link between the alleged fraud and the claimed damages. View "US Framing International LLC v. Continental Building Co." on Justia Law

Dwayne Robinson was convicted by a jury for unlawfully possessing a firearm as a felon. The district court imposed the Armed Career Criminal Act’s (ACCA) minimum punishment, finding that Robinson had three prior qualifying offenses committed on different occasions. Robinson appealed, raising four claims: a Sixth Amendment violation due to the district court responding to a jury note without his counsel’s input, the court’s failure to grant a mistrial after detectives implied he had shot at someone, incorrect jury instructions regarding gun ownership and possession, and the district court’s application of the ACCA without a jury determination on whether his prior offenses occurred on different occasions.The United States District Court for the Middle District of Tennessee at Nashville initially reviewed the case. Robinson did not properly object to the court’s response to the jury note, the failure to grant a mistrial, or the jury instructions, leading to a review for plain error. The district court found Robinson’s three prior offenses occurred on different occasions, thus applying the ACCA’s mandatory minimum sentence.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Robinson’s failure to object to the jury note response, mistrial denial, and jury instructions meant these issues were reviewed for plain error. The court found no obvious mistakes in these areas. Regarding the ACCA application, the court acknowledged intervening Supreme Court precedent requiring a jury to determine if prior offenses occurred on different occasions. However, the court found this error harmless because the record clearly showed Robinson’s offenses were separated by many years. Thus, the Sixth Circuit affirmed the district court’s judgment. View "United States v. Robinson" on Justia Law

Plaintiffs, thirty-eight current and former engineers employed by FCA US LLC (FCA), were transferred from the Chrysler Technical Center to the Trenton Engine Complex in 2011. They alleged that this transfer violated the collective bargaining agreement (CBA) and filed grievances with the International Union, United Automobile, Aerospace and Agricultural Implement Workers of America (UAW). These grievances were denied, and Plaintiffs later discovered a bribery scheme between FCA and UAW officials, which they claimed influenced the handling of their grievances.The United States District Court for the Eastern District of Michigan denied Plaintiffs' motion to remand their state-law claims to state court, finding that the claims were completely preempted by Section 301 of the Labor Management Relations Act (LMRA). The court held that the claims required interpretation of the CBA and were thus preempted. Plaintiffs then stipulated to the dismissal of their complaint but reserved the right to appeal the remand decision.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 Plaintiffs' state-law claims for fraud, breach of fiduciary duty, and civil conspiracy were completely preempted by Section 301 of the LMRA. The court reasoned that the claims were based on rights created by the CBA and required interpretation of its terms. Consequently, the claims had to be heard in federal court. The court also rejected Plaintiffs' arguments for remand based on Michigan criminal laws and Section 9(a) of the National Labor Relations Act (NLRA). View "Baltrusaitis v. UAW" on Justia Law